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May 2007 


Developing Your Stormwater 
Pollution Prevention Plan 

A Guide for Construction Sites 







Developing Your Stormwater Pollution Prevention Plan 

A Guide for Construction Sites 

Who? i 

Construction site operators (generally, the person who has operational control over construction plans and/or 
the person who has day-to-day supervision and control of activities occurring at the construction site) 

Where? 

Construction sites required to comply with stormwater discharge requirements 


What? 

A guide to help you develop a good Stormwater Pollution Prevention Plan (SWPPP) 


Why? 

Stormwater runoff from construction sites can cause significant harm to our rivers, lakes, and coastal waters 

A SWPPP is required (by your construction general permit) and will help you prevent stormwater pollution 

A SWPPP is more than just a sediment and erosion control plan. 

It describes all the construction site operator’s activities to prevent stormwater contamination, control 
sedimentation and erosion, and comply with the requirements of the Clean Water Act 


Purpose of this Guidance Document 


This document provides guidance to construction site operators that need to prepare a SWPPP in order to 
receive NPDES permit coverage for their stormwater discharges. The Clean Water Act provisions, EPA regulations 
and EPA's Construction General Permit described in this document contain legally binding requirements. This 
document does not substitute for those provisions, regulations or permit, nor is it a regulation or permit itself. It also 
does not substitute for requirements under State law or construction general permits issued by States. It does not 
impose legally-binding requirements on EPA, States, or the regulated community, and may not apply to a particular 
situation based upon the circumstances. EPA and State decisionmakers retain the discretion to adopt approaches 
on a case-by-case basis that differ from this guidance where appropriate. Any decisions regarding a particular 
construction site will be made based on the applicable statutes, regulations and/or permit terms. Therefore, interested 
parties are free to raise questions and objections about the appropriateness of the application of this guidance to 
a particular situation, and EPA—or the applicable NPDES permitting authority—will consider whether or not the 
recommendations or interpretations in the guidance are appropriate in that situation based on the law and regulations. 


This guidance document occasionally uses language describing mandatory requirements for construction 
site operators and those covered by a general permit for stormwater discharges from such sites. This language 
is generally intended to reflect requirements applicable where EPA is the NPDES permitting authority. Although 
requirements in jurisdictions where EPA is not the permitting authority may resemble these requirements, the reader 
should not assume that this guidance accurately describes those requirements. Rather, the reader should consult 
the applicable regulations and any applicable NPDES permit. 


LC Control Number 



2007 467160 


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Contents 


Chapter 1: Introduction. 

A. Why Should You Use this Guide?. 

B. What Is Stormwater Runoff and What Are Its Impacts?. 

C. How Can Construction Site Operators Prevent Stormwater Pollution?. 

Chapter 2: Getting Started.. 

A. What Are the Federal Requirements for Stormwater Runoff from Construction Sites? 

B. Who Is Required to Get NPDES Permit Coverage?. 

C. What Elements Are Required in a SWPPP?. 

D. SWPPP Roles and Responsibilities. 

E. Common SWPPP Objectives. 








Chapter 3: SWPPP Development—Site Assessment and Planning 

A. Assess Your Site and Proposed Project. 

B. Identify Approaches to Protect Natural Resources. 

C. Develop Site Maps. 


Chapter 4: SWPPP Development—Selecting Erosion and Sediment Control BMPs 
Chapter 5: SWPPP Development—Selecting Good Housekeeping BMPs. 

Chapter 6: SWPPP Development—Inspections, Maintenance, and Recordkeeping 

A. Describe Your Plans and Procedures for Inspecting BMPs . 

B. BMP Maintenance. 

C. Recordkeeping. 


Chapter 7: Certification and Notification 

A. Certification. 

B. Notification. 


Chapter 8: SWPPP Implementation. 

A. Train Your Staff and Subcontractors. 

B. Ensure Responsibility—Subcontractor Agreements. 

C. Implement Your SWPPP Before Construction Starts. 

D. Conduct Inspections and Maintain BMPs. 

E. Update and Evaluate Your SWPPP. 

Chapter 9: Final Stabilization and Permit Termination 

A. Final Stabilization . 

B. Permit Termination . 

C. Record Retention. 


References. 

Appendices 

Appendix A - SWPPP Template (available at www.epa.gov/npdes/swpppguide) 
Appendix B - Inspection Report (available at www.epa.gov/npdes/swpppguide) 

Appendix C - Calculating the Runoff Coefficient. 

Appendix D - Resources List. 


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Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


i 











































What is a Stormwater Pollution Prevention Plan (SWPPP)? 


A SWPPP may be called many things. Your state may use terms like: 

• Construction Best Practices Plan 

• Sediment and Stormwater Plan 

• Erosion, Sediment, and Pollution Prevention Plan 

• Construction Site Best Management Practices Plan 

• Erosion Control Plan and Best Management Practices 

• Best Management Practices Plan 

• Erosion and Sediment Control Plan 

Regardless of the title used in your state, these documents—and the 
stormwater permits that require them—tend to have many common 
elements. This guide is intended to help you develop a better SWPPP for your 
construction site. 



Example sketch identifying various points to 
address in the SWPPP. 


How to Use This Guide 

■ This guide was developed as a helpful reference guide for construction site operators across 
the country. We have tried to accommodate the wide range of knowledge and experience 
about stormwater pollution prevention that currently exists among operators—from novice to 
expert. 

• If you are relatively new to managing stormwater at a construction site, you will probably 
want to read this entire guide. 

• If you are very experienced and familiar with the requirements in your state, this guide 
may help you brush up on certain requirements or provide you with ideas to improve 
your SWPPP. You might want to review the table of contents and skip around. Be sure to 
take a look at the SWPPP template (Appendix A) to see if you can make improvements in 
the way you develop and maintain your SWPPP. 

■ This guide is written in a general format and can be used at most construction sites in any 
state, territory, or in Indian country. The document assumes that you will obtain discharge 
authorization under an appropriate National Pollutant Discharge Elimination System (NPDES) 
construction general permit and use both the permit and this guidance to assist in developing 
your SWPPP. In this guide, we make some references to the U.S. Environmental Protection 
Agency’s Construction General Permit for illustrative purposes. You should always consult 
your applicable NPDES permit for the exact requirements that apply to you. 

■ Remember that you are developing your SWPPP for both your use and for review by the 
regulatory agencies responsible for overseeing your stormwater controls. As such, one of your 
goals in developing your SWPPP should be to present the information in a way that clearly 
demonstrates that it meets all the requirements of your NPDES permit. 

■ You can obtain an electronic copy of this guide (PDF format), the SWPPP template, and 
inspection form (in Microsoft Word) at www.epa.gov/npdes/swpppguide 


ii 


Developing Your Stormwater Pollution Prevention Plan-. A Guide for Construction Sites 





Chapter 1: Introduction ► This chapter provides 

1 an orientation to this 

guide and its contents 
and describes why 
stormwater controls 
at construction sites 

A. Why Should You Use this Guide? are necessary - 

If you are responsible for erosion and sediment control and stormwater management 
at a permitted construction site, then this guide may be useful to you. This guide is 
designed to walk you through the steps for developing and implementing an effective 
stormwater pollution prevention plan (SWPPP). The basic outline of the guide is 
presented below: 


SWPPP Development 



Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


1 






























Take a Closer Look... 

What is a SWPPP? 

A SWPPP is a site-specific, written document that: 

• Identifies potential sources of stormwater pollution at the construction site 

• Describes practices to reduce pollutants in stormwater discharges from the 
construction site. Reduction of pollutants is often achieved by controlling the volume 
of stormwater runoff (e.g., taking steps to allow stormwater to infiltrate into the soil). 

• Identifies procedures the operator will implement to comply with the terms and 
conditions of a construction general permit 


What does this mean to me? 

Failure to implement your SWPPP 
could result in significant fines 
from EPA or a state environmental 
agency. Therefore, it is important 
that you develop your SWPPP to 
address the specific conditions 
at your site, fully implement it, 
and keep it up-to-date to reflect 
changes at your site. 


B. What Is Stormwater Runoff and What 
Are Its Impacts? 

Stormwater runoff is rain or snowmelt that 
flows over land and does not percolate into the 
soil. Stormwater runoff occurs naturally, in 
small amounts, from almost any type of land 
surface, especially during larger storm events. 


A SWPPP can have different names 

A SWPPP may also be called a " construction 
best practices plan," ‘‘sediment and stormwater 
plan," ‘‘erosion, sedimentation, and pollution 
prevention plan," or similar term. The SWPPP 
(or similarly named plan) is generally required 
to comply with EPA’s or the state’s stormwater 
construction general permit. 

increasing the volume, velocity, and 
temperature of runoff and by decreasing its 
infiltration capacity. Increasing the volume 
and velocity of stormwater runoff can cause 
severe stream bank erosion, flooding, and 
degrade the biological habitat of these streams. 
Reducing infiltration can lower ground water 
levels and affect drinking water supplies. 

In addition, as stormwater runoff moves 
across surfaces, it picks up trash, debris, 
and pollutants such as sediment, oil and 
grease, pesticides and other toxics. Changes 
in ambient water temperature, sediment, 
and pollutants from stormwater runoff 
can be detrimental to aquatic life, wildlife, 
habitat, and human health. Soil exposed by 
construction activities is especially vulnerable 
to erosion. Runoff from an unstabilized 
construction site can result in the loss of 
approximately 35-45 tons of sediment per 
acre each year (ASCE and WFF, 1992). Even 
during a short period of time, construction 
sites can contribute more sediment to streams 
than would be deposited naturally over several 


¥ SWPPP Tip! 


Impervious 
surfaces, such 
as buildings, 
homes, roads, 
sidewalks, 
and parking 
lots, can 
significantly 
alter the 
natural 
hydrology of 
the land by 


decades. Excess sediment can cloud the water 
reducing the amount of sunlight reaching 
aquatic plants, clog fish gills, smother aquatic 
habitat and spawning areas, and impede 
navigation in our waterways. 

The primary stormwater pollutant at a 
construction site is sediment. To control 
erosion at a construction site, it is important 
to understand the different types of erosion 
that can occur. Erosion begins when raindrops 
break down the soil structure and dislodge 
soil particles. Runoff carrying the soil particles 
becomes sheet erosion which eventually forms 
smaller rills and larger gullies. The best way 
to stop erosion is to keep the soil in place 
through vegetation, erosion control blankets, 
or other methods that prevent the soil from 
becoming dislodged during rain events. 

The erosion process is typically influenced 
by climate, topography, soils, and vegetative 
cover. Understanding how these factors influ¬ 
ence erosion will help you select and design 
appropriate controls to minimize erosion from 
your construction site. 


Typical erosion rates for 
land-based activities 

(soil loss from various land areas, 
in tons per acre per year) 


Bare Soil 
(e.g., unmanaged 
construction sites) 


- 35 - 


Farm Land 
(row crop) 



2V. 





Figure 2. Typical erosion rates from land-based activities. 
(Dunne, T. and L. Leopold, 1978; NRCS, 2000; NRCS, 
2006; ASCE and WEF, 1992) 


2 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 











Climate. The frequency, intensity, and 
duration of rainfall are the principal factors 
influencing erosion from a construction site. 
Know the weather patterns in your area and, if 
possible, plan your soil disturbance activities 
for periods of historically lower rainfall. 

Topography. The longer and steeper a 
slope, the greater the potential there is for 
erosion from that slope. Use practices such 
as diversions or fiber rolls to break up long 
slopes. Consider minimizing soil disturbance 
activities on steeper slopes. 

Soils. Soil type can also impact erosion. Soil 
texture, structure, organic matter content, 
compaction, and permeability can all 
influence erosion rates. 

Vegetative cover. Vegetative cover provides 
a number of critical benefits in preventing 
erosion—it absorbs the energy of raindrops, 
slows velocity of runoff, increases infiltration, 
and helps bind the soil. Soil erosion can be 
greatly reduced by maximizing vegetative 
cover at a construction site. 

C. How Can Construction Site Operators 
Prevent Stormwater Pollution? 

An effective SWPPP is the key! If sediment 
and erosion controls and good housekeeping 
practices are not followed, construction activity 
can result in the discharge of significant 
amounts of sediment and other pollutants. 

The term Best Management Practices or BMPs 
is often used to describe the controls and 
activities used to prevent stormwater pollution. 


Figure 3. Types of erosion. 

Raindrop erosion 

Dislodging of soil particles by raindrops 

Sheet erosion 

The uniform removal of soil without the development of visible 
water channels 

Rill erosion 

Soil removal through the formation of concentrated runoff that 
creates many small channels 

Gully erosion 

The result of highly concentrated runoff that cuts down into the 
soil along the line of flow 

Streambank erosion 

Flowing water that erodes unstable streambanks 




SWPPP Tip! 


Erosion versus Sedimentation 


Erosion is the process by which the land surface 
is worn away by the action of water or wind. 
Sedimentation is the movement and settling out 
of suspension of soil particles. It is usually easier 
and less expensive to prevent erosion than it is to 
control sediment from leaving a construction site. 


BMPs can be divided into two categories— 
structural and non-structural BMPs. Structural 
BMPs include silt fences, sedimentation ponds, 
erosion control blankets, and temporary or 
permanent seeding, while non-structural 
BMPs include picking up trash and debris, 
sweeping up nearby sidewalks and streets, 
maintaining equipment, and training site staff 
on erosion and sediment control practices. 

In this document, the term “BMPs” is used 
broadly and includes both structural and non- 
structural controls and practices. 

A SWPPP is more than just a sediment 
and erosion control plan. Most SWPPPs 
are written documents that describe the 
pollution prevention practices and activities 
that will be implemented on the site. It 
includes descriptions of the site and of each 
major phase of the planned activity, the 
roles and responsibilities of contractors and 
subcontractors, and the inspection schedules 
and logs. It is also a place to document 
changes and modifications to the construction 
plans and associated stormwater pollution 
prevention activities. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


3 










Chapter 2: Getting Started 


A. What Are the Federal Requirements for Stormwater Runoff from 
Construction Sites? 

The Clean Water Act and associated federal regulations (Title 40 of the Code of Federal 
Regulations [CFR] 123.25(a)(9), 122.26(a), 122.26(b)(14)(x) and 122.26(b)(15)) require 
nearly all construction site operators engaged in clearing, grading, and excavating 
activities that disturb one acre or more, including smaller sites in a larger common 
plan of development or sale, to obtain coverage under a National Pollutant Discharge 
Elimination System (NPDES) permit for their stormwater discharges. Under the 
NPDES program, the U.S. Environmental Protection Agency (EPA) can authorize 
states to implement the federal requirements and issue stormwater permits. Today, 
most states are authorized to implement the NPDES program and issue their own 
permits for stormwater discharges associated with construction activities. 


M 


SWPPP Tip! 


Don’t forget about “common plans of 
development or sale” 

A common plan of development or sale includes 
larger-scale plans for land development to be 
carried out by one or more entities. Examples 
include housing developments and subdivisions, 
industrial parks, and commercial developments. 

EPA has described this term in the fact sheet 
accompanying its Construction General Permit 
as including: any announcement or piece of 
documentation (including a sign, public notice 
or hearing, sales pitch, advertisement, drawing, 
permit application, zoning request, computer 
design, etc.), or physical demarcation (including 
boundary signs, lot stakes, surveyor markings, 
etc.) indicating construction activities may occur 
on a specific plot. Each permitting authority may 
review documentation to determine if common 
plan requirements apply. 


Each state (or EPA, in the case 
of states that are not authorized) 
issues one or more NPDES 
construction general permits. These 
permits, generally, can be thought 
of as umbrella permits that cover all 
stormwater discharges associated 
with construction activity in a 
given state for a designated time 
period, usually 5 years. Operators 
of individual constructions sites 
then apply for coverage under this 
permit. Before applying for permit 
coverage, you should read and 
understand all the provisions of the 
appropriate construction general 
permit and develop a SWPPP. 
Because authorized states develop 
their own NPDES requirements, 
you should carefully read your 
state’s construction general 
permit and follow the specific 
instructions it contains. 


► This chapter 
describes some of 
the basic things you’ll 
want to determine 
(Do you need permit 
coverage? What 
permit applies to 
you?), as well as some 
of the materials and 
information you may 
need to develop your 
SWPPP. Collecting this 
information before 
you start will help you 
develop your SWPPP 
more efficiently. Keep 
in mind that you may 
also need to gather 
this information and 
develop your SWPPP 
before you complete 
your Notice of Intent 
(NOI) and file for 
permit coverage (note 
that filing an NOI is 
not discussed until 
Chapter 7). 


Take a Closer Look... 

EPA Permits vs. State-Issued Permits 

At the time of publication, EPA was the NPDES permitting authority in 
Massachusetts, New Hampshire, New Mexico, Idaho, Alaska, the District 
of Columbia, Puerto Rico, the U.S. territories (except the Virgin Islands), 
most Indian country lands, and for federal facilities in four states. For an 
up-to-date list of NPDES permitting authorities, visit www.epa.gov/npdes/ 
stormwater/construction or www.cicacenter.org/swrl.html 


What does this mean to me? 

Because EPA and state-issued permits can 
be different, you should make sure you read 
and apply for the correct permit. Use the 
links on either of the web sites listed to the 
left to determine which agency issues NPDES 
permits where your construction activity will 
occur. 


4 


■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ 


Developing Your Stormwater Pollution Prevention Plan-. A Guide for Construction Sites 







Most construction general permits contain 
similar elements: 

• Applicability—describes the geographic 
area covered and who is eligible to apply 

• Authorization—describes the types 
of stormwater (and non-stormwater) 
discharges that are covered 

• SWPPP requirements—outlines the 
elements that should to be addressed to 
prevent the contamination of stormwater 
runoff leaving the construction site 

• Application—includes instructions for 
obtaining permit coverage, usually by filing 
an application or Notice of Intent (NOI) form 

• Implementation—BMP installation, 
inspection, and maintenance requirements 

• Other requirements—may include 
additional requirements such as spill 
prevention 

• Standard conditions—list of conditions that 
are applicable to most NPDES permits 

• Termination—lists conditions for 
terminating permit coverage after 
construction is complete 

What Construction Activities Require NPDES 
Permit Coverage? 

In this document, “construction’' refers to 
actions that result in a disturbance of the 
land, including clearing, grading, excavating, 
and other similar activities. It also includes 
“construction-related activities,’’ areas that 
support the construction project such as 
stockpiles, borrow areas, concrete truck 
washouts, fueling areas, material storage 
areas and equipment storage areas. 

Construction activities that do not disturb 
land, such as interior remodeling, generally 
do not require NPDES permit coverage. 

Are There Situations Where a Permit Is Not 
Needed? 

Generally, permit coverage is not required 
for activities that are considered routine 
maintenance, such as landscaping, road 
maintenance, and maintaining stormwater 
BMPs. Some states and EPA offer the option 
of a waiver for small sites (disturbing less 
than 5 acres) in areas and times of the year 
with low predicted rainfall. To be eligible 
for the waiver, you would have to meet the 
requirements specified in the regulations. 


Local Requirements 

Operators of construction sites should keep in 
mind that local governments (cities, towns, 
counties) often have their own requirements 
for construction sites (e.g., local permits for 
grading, sediment and erosion, utilities). 
Compliance with local requirements 
does not mean compliance with federal 
NPDES requirements or vice versa, unless 
the authorized state agency or EPA has 
specifically designated the local program a 
qualifying local program. 

Qualifying Local Programs 

In some states, the NPDES permitting agency 
has identified certain local construction 
stormwater control programs that have 
requirements that are equivalent or more 
protective than the state’s requirements. If 
one of these local stormwater programs has 
been designated by the permitting agency as a 
qualifying local program, the construction site 
operator may simply read and follow the local 
requirements. The permitting agency (state or 
EPA) might choose to waive the requirement 
to file a Notice of Intent (NOI) or similar 
application form for small construction 
sites operating within the jurisdiction of a 
qualifying local program. If waived, these 
sites would be covered under the appropriate 
construction general permit automatically. 
Check your construction general permit 
carefully. 

The NPDES permitting authority must 
identify any qualifying local programs in the 
construction general permit. Violations of 
the local requirements are also considered 
violations of the NPDES requirements and 
may be enforced accordingly. 


SWPPP Tip! 


Read Your General Permit! 

You should thoroughly read and understand 
the requirements in your general permit. This 
includes requirements on eligibility (whether 
your site qualifies for the general permit), 
application (how to notify EPA or the state that 
you’d like to be covered by the general permit), 
SWPPPs, and termination (stabilizing your site 
and notifying EPA or the state that your project 
is complete). By applying for coverage under 
the general permit, you are telling EPA or your 
state that you will comply with the permit’s 
requirements, so read your permit carefully! 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


5 




B. Who Is Required to Get NPDES Permit 
Coverage? 

Construction site operators are responsible 
for obtaining NPDES permit coverage 
for their stormwater discharges. Each 
state has its own definition of the term 
operator. Operators may include owners 
(e.g., developers), general contractors, 
independent subcontractors, government 
officials, companies, or corporations. This 
section reflects EPA’s understanding of most 
NPDES permit requirements for stormwater 
discharges throughout the country. You 
should, of course, consult your construction 
general permit for the requirements that apply 
to you. In some cases, states have defined the 
operator as a single entity, usually the land 
owner or easement holder. In other states, 
several entities may meet the definition of 
operator. For instance, the owner may control 
the project’s plans and specifications, and 
the general contractor may control the site’s 
day-to-day operations. In such cases, both 
may be defined as operators. If a site has 
multiple operators, they may cooperate on the 
development and implementation of a single 
SWPPP. Operators generally obtain coverage 
under an NPDES permit, often by filing a form 
called a Notice of Intent (NOI). 



Figure 4. Use signage to help educate construction staff. 


EPA’s Construction General Permit (which 
applies only where EPA is the permitting 
authority—see Chapter 2 Section A) defines 
operator as any party that: 

• Has control over the construction plans and 
specifications 

and/or 

• Has day-to-day operational control of 
the site, including activities necessary to 
implement the SWPPP 

Regardless of whether or not the operator is a 
corporation or governmental entity, someone 
must direct the SWPPP’s preparation and 
implementation and apply for NPDES permit 
coverage for the stormwater discharges. In 
most cases, this will be a high-level official, 
such as a corporate officer, manager or elected 
official, or a principal executive officer. For 
specific instructions, refer to the appropriate 
NPDES stormwater permit. 

Multiple Operators 

In many instances, there may be more 
than one party at a site performing tasks 
related to operational control and more than 
one operator may need to submit an NOI. 
Depending on the site and the relationship 
between the parties (e.g., owner, developer, 
general contractor), there can either be 
a single party acting as site operator and 
consequently responsible for obtaining 
permit coverage, or there can be two or 
more operators all needing permit coverage. 
Exactly who is considered an operator is 
largely controlled by how the owner of the 
project chooses to structure the contracts with 
the contractors hired to design and/or build 
the project. The following are three general 
operator scenarios (variations on any of these 
three are possible, especially as the number of 
owners and contractors increases): 

• Owner as sole permittee. The property 
owner designs the structures for the site, 
develops and implements the SWPPP, and 
serves as general contractor (or has an 
on-site representative with full authority to 
direct day-to-day operations). The owner 
may be the only party that needs permit 
coverage under these circumstances. 
Everyone else on the site may be 
considered subcontractors and might not 
need permit coverage. 


6 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 












• Contractor as sole permittee. The property 
owner hires one company (i.e., a contractor) 
to design the project and oversee all aspects 
of the construction project, including 
preparation and implementation of the 
SWPPP and compliance with the permit 
(e.g., a turnkey project). Here, the contractor 
would likely be the only party needing a 
permit. It is under this scenario that an 
individual having a personal residence built 
for his own use (e.g., not those to be sold 
for profit or used as rental property) would 
not be considered an operator. However, 
individual property owners would meet 
the definition of operator and may require 
permit coverage if they perform general 
contracting duties for construction of their 
personal residences. 

• Owner and contractor as co-permittees. The 
owner retains control over any changes 

to site plans, SWPPPs, or stormwater 
conveyance or control designs; but the 
contractor is responsible for overseeing 
actual earth disturbing activities and daily 
implementation of SWPPP and other permit 
conditions. In this case, which is the most 
common scenario, both parties may need 
to apply for permit coverage. 

However, you are probably not an operator 
and subsequently would not need permit 
coverage if one of the following is true: 

• You are a subcontractor hired by, and 
under the supervision of, the owner or a 
general contractor (i.e., if the contractor 
directs your activities on-site, you probably 
are not an operator) 

• The operator of the site has indicated in 
the SWPPP that someone other than you 
(or your subcontractor) is reponsible for 
your activities as they relate to stormwater 
quality (i.e., another operator has assumed 
responsibility for the impacts of your 


construction activities). This is typically 
the case for many, if not most, utility 
service line installations. 

In addition, owner typically refers to the 
party that owns the structure being built. 
Ownership of the land where construction 
is occurring does not necessarily imply 
the property owner is an operator (e.g., a 
landowner whose property is being disturbed 
by construction of a gas pipeline). Likewise, if 
the erection of a structure has been contracted 
for, but possession of the title or lease to the 
land or structure does not to occur until after 
construction, the would-be owner may not be 
considered an operator (e.g., having a house 
built by a residential homebuilder). 

Transferring Ownership 

In many residential developments, an 
overall developer applies for the stormwater 
permit coverage, conducts grading activities, 
and installs the basic infrastructure (e.g., 
utilities, roads). Individual lots are then sold 
to builders who then construct the houses. 
Unless the developer is still responsible for 
stormwater on these individual lots (which 
is typically not the case), it is likely that the 
builder will need to apply for NPDES permit 
coverage for stormwater discharges during 
home construction. 

Subcontractors 

It is typically a good idea to include specific 
contract language requiring subcontractors 
to implement appropriate stormwater 
controls. Subcontractors should be trained 
on appropriate BMPs and requirements in 
the SWPPP and should not disturb or remove 
BMPs. Some contractors will include specific 
penalties in subcontractor agreements to 
ensure subcontractors do not damage or 
remove BMPs. 


Take a Closer Look... 

Erosion Control vs. Sediment Control 

When developing a SWPPP, it is important to understand the difference 
between erosion control and sediment control. Erosion control measures 
(e.g., mulch, blankets, mats, vegetative cover) protect the soil surface and 
prevent soil particles from being dislodged and carried away by wind or 
water. Sediment control measures remove soil particles after they have been 
dislodged (typically through settling or filtration). It is usually easier and less 
expensive to prevent erosion than it is to control sedimentation. 


What does this mean to me? 

You should try to use erosion control 
BMPs as the primary means of preventing 
stormwater contamination, and sediment 
control techniques to capture any soil 
that does get eroded. Because no one 
technique is 100 percent effective, a 
good SWPPP will use both kinds of BMPs 
in combination for the best results. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


7 




C. What Elements Are Required in a 
SWPPP? 

The SWPPP lays out the steps and techniques 
you will use to reduce pollutants in 
stormwater runoff leaving your construction 
site. Therefore, proper development and 
implementation of your SWPPP is crucial. 

First and foremost, your SWPPP must be 
developed and implemented consistent 
with the requirements of the applicable 
NPDES stormwater construction permit. The 
following discussion describes requirements 
that are contained in most of these permits. 

Your SWPPP is used to identify all potential 
pollution sources that could come into contact 
with stormwater leaving your site. It describes 
the BMPs you will use to reduce pollutants 
in your construction site’s stormwater 
discharges, and it includes written records 
of your site inspections and the follow-up 
maintenance that is performed. 

Your SWPPP should contain the following 
elements: 

• Cover/title page 

• Project and SWPPP contact information 

• Site and activity description, including a 
site map 

• Identification of potential pollutant sources 

• Description of controls to reduce pollutants 

• Maintenance/inspection procedures 

• Records of inspections and follow-up 
maintenance of BMPs 

• SWPPP amendments 

• SWPPP certification 

Chapters 3-6 of this guide describe how to 
develop a SWPPP—from site evaluation and 
data collection to selecting appropriate BMPs 
and assigning maintenance and inspection 
responsibilities. 


D. SWPPP Roles and Responsibilities 

The operator has the lead for developing and 
implementing the SWPPP and commuting 
resources to implement the BMPs. Stormwater 
pollution control is typically the job of more 
than a single person; the SWPPP development 
process provides a good opportunity to 
define roles and responsibilities of everyone 
involved. Roles and responsibilities are to 
be documented clearly in the SWPPP and 
subcontractor agreements as necessary. Your 
SWPPP should describe: 

• Who is on the stormwater pollution 
prevention team? 

• Who will install structural stormwater 
controls? 

• Who will supervise and implement 
good housekeeping programs, such as 
site cleanup and disposal of trash and 
debris, hazardous material management 
and disposal, vehicle and equipment 
maintenance, and so on? 

• Who will conduct routine inspections 
of the site to ensure all BMPs are being 
implemented and maintained? 

• Who will maintain the BMPs? 

• Who is responsible for documenting 
changes to the SWPPP? 

• Who is responsible for communicating 
changes in the SWPPP to people working 
on the site? 

When you apply for your stormwater permit, 
the application may ask for a SWPPP 
contact. This could be the construction 
site operator, but in many cases it’s a staff 
person (e.g., project superintendent, field 
manager, construction manager, stormwater 
compliance officer) at the construction site 
who is responsible for conducting inspections, 
ensuring BMPs are installed and maintained, 
and updating the SWPPP when necessary. 


SWPPP Tip! 


Erosion Control Certification 

Several programs promote the training and 
certification of individuals in erosion and sediment 
control. Some states have developed certification 
programs and require construction sites to have a 
certified individual on-site at all times. The Soil and 
Water Conservation Society and the International 
Erosion Control Association sponsor a national 
certification program, the Certified Professional in 
Erosion and Sediment Control (www.cpesc.org) 


8 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 





■■■■■■■■■■■■■■ 


E. Common SWPPP Objectives 

The SWPPP outlines the steps you will take 
to comply with the terms and conditions of 
your construction general permit. Keeping the 
following objectives in mind as you develop 
your SWPPP will help guide you in addressing 
your permit requirements and in protecting 
water quality. 

• Stabilize the site as soon as possible. 

Get your site to final grade and either 
permanently or temporarily stabilize all 
bare soil areas as soon as possible. Take 
into consideration germination times for the 
grasses or other vegetation selected, and 
provide additional stabilization (mulches, 
matrices, blankets, soil binders) on erosion- 
prone areas such as slopes and drainage 
ways. Also consider seasonal limitations 

to plant establishment and growth, such 
as drought or cold temperatures, and 
make an effort to ensure that areas that 
are not showing adequate vegetation 
establishment are reseeded or mulched 
immediately. Areas needed for future roads, 
construction, or other purposes should be 
temporarily stabilized (see your permit for 
requirements related to areas of the site 
not currently under active construction). 
Establishing a vegetated cover on as much 
of the site as possible will help to minimize 
erosion and sediment problems. Perimeter 
controls should remain in place until final 
stabilization has been achieved. 

• Protect slopes and channels. Convey 
concentrated stormwater runoff around 
the top of slopes and stabilize slopes as 
soon as possible. This can be accomplished 
using pipe slope drains or earthen berms 
that will convey runoff around the exposed 
slope. Avoid disturbing natural channels 


and the vegetation along natural channels, 
if possible. 

• Reduce impervious surfaces and promote 
infiltration. Reducing impervious surfaces 
will ultimately reduce the amount of 
runoff leaving your site. Also, divert 
runoff from rooftops and other impervious 
surfaces to vegetated areas when possible 
to promote infiltration. 

• Control the perimeter of your site. Divert 
stormwater coming on to your site by 
conveying it safely around, through, or 
under your site. Avoid allowing run-on to 
contact disturbed areas of the construction 
site. For the runoff from the disturbed 
areas of the site, install BMPs such as silt 
fences to capture sediment before it leaves 
your site. Remember—“Divert the clean 
water, trap the dirty water.” 

• Protect receiving waters adjacent to your 
site. Erosion and sediment controls are 
used around the entire site, but operators 
should consider additional controls 

on areas that are adjacent to receiving 
waters or other environmentally sensitive 
areas. Remember, the primary purpose 
of erosion and sediment controls is to 
protect surface waters. 

• Follow pollution prevention measures. 
Provide proper containers for waste and 
garbage at your site. Store hazardous 
materials and chemicals so that they are 
not exposed to stormwater. 

• Minimize the area and duration of exposed 
soils. Clearing only land that will be under 
construction in the near future, a practice 
known as construction phasing, can reduce 
off-site sediment loads by 36 percent for 

a typical subdivision (Claytor 2000). 
Additionally, minimizing the duration of 
soil exposure by stabilizing soils quickly 
can reduce erosion dramatically. 


Take a Closer Look... 

Incentives to preserve open space 

It should be the goal of every construction 
project to, where possible, preserve open 
space and minimize impervious surfaces 
through practices such as clustering houses. 
Open space preservation can provide 
significant water quality and economic 
benefits to property owners. 


What does this mean to me? 

From a marketing perspective, studies have shown that lots abutting 
forested or other open space are initially valued higher than lots with 
no adjacent open space, and over time their value appreciates more 
than lots in conventional subdivisions (Arendt 1996). For example, lots 
in an open space subdivision in Amherst, Massachusetts, experienced 
a 13 percent greater appreciation in value over a comparable 
conventional development after 20 years even though the lots in the 
conventional development were twice as large (Arendt 1996). 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


9 









Chapter 3. SWPPP Development—Site 
Assessment and Planning 


This chapter describes a number of steps that will help provide a good foundation for 
your SWPPP, including: 

• Assessing current conditions at the site 

• Establishing pollution prevention and water quality protection goals for your 
project 

• Developing a framework to help you meet those goals 

A. Assess Your Site and Proposed Project 

The first step in developing your SWPPP is to evaluate your 
proposed construction site. Your SWPPP should describe the 
undeveloped site and identify features of the land that can 
be incorporated into the final plan and natural resources 
that should be protected. Understanding the hydrologic and 
other natural features of your site will help you develop a 
better SWPPP and, ultimately, to more effectively prevent 
stormwater pollution. 

Visit the Site 

The people responsible for site design and drafting the 
SWPPP should conduct a thorough walk-through of the entire 
construction site to assess site-specific conditions such as soil 
types, drainage patterns, existing vegetation, and topography. 

Avoid copying SWPPPs from other projects to save time or 
money. Each construction project and SWPPP is unique, 
and visiting the site is the only way to create a SWPPP that 
addresses the unique conditions at that site. 

Assess Existing Construction Site Conditions 

Assess the existing conditions at the construction site, including topography, 
drainage, and soil type. This assessment, sometimes called fingerprinting (see text 
box on page 11) is the foundation for building your SWPPP and for developing your 
final site plan. In this assessment, use or create a topographic drawing that: 

• Indicates how stormwater currently drains from the site, and identify the location 
of discharge points or areas 

• Identifies slopes and slope lengths. The topographic features of the site are a major 
factor affecting erosion from the site 

• Identifies soil type(s) and any highly erodible soils and the soil’s infiltration 
capacity 

• Identifies any past soil contamination at the site 

• Identifies natural features, including trees, streams, wetlands, slopes and other 
features to be protected 


SWPPP Tip! 


A SWPPP is a detailed plan that: 

• Identifies potential sources of stormwater 
pollution 

• Describes the practices that will be used 
to prevent stormwater pollution. These 
should include: erosion and sediment control 
practices, good housekeeping practices, 
conservation techniques, and infiltration 
practices (where appropriate), and 

• Identifies procedures the operator will 
implement to comply with all requirements 
in the construction general permit 


► The first step in 
developing a SWPPP 
is assessing the 
site and identifying 
measures to protect 
natural features. 


10 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 





Take a Closer Look... 

Fingerprinting Your Site 

What does this mean to me? 

Fingerprinting your site will help 
ensure that you don’t damage natural 
features such as waterways or wetlands. 
Conducting construction activity in a 
waterway or wetland without the proper 
permits can result in significant penalties. 


When you evaluate your construction site, you should clearly identify 
vegetation, trees, and sensitive areas, such as stream buffers, wetlands, 
highly erodible soils, and steep slopes at your site. You should protect these 
areas from disturbance. Inventorying a site’s natural features is a technique 
called fingerprinting. Fingerprinting identifies natural features that you can 
protect from clearing and heavy equipment by signage or physical barriers. 


In most cases, the site designer can compile 
all this information on a digitized drawing 
that can then be adapted to show the 
planned construction activity, the phases of 
construction, and the final site plan. 

Topographic maps are readily available on 
the Internet (e.g., www.terraserver.com or 
www.mapquest.com) or by contacting the 
U.S. Geological Survey store (http://store. 
usgs.gov). If you need help determining 
your soil type, contact your local Natural 
Resource Conservation Service (NRCS) office 
or extension service office. To find the NRCS 
office nearest to your site, visit the U.S. 
Department of Agriculture’s Service Center 
Locator website (http://offices.sc.egov.usda. 
gov/locator/app). Soil information is also 
available online from NRCS (http://soils. 
usda.gov). 

Identify Receiving Waters , Storm Drains , and 
Other Stormwater Conveyance Systems 

Your SWPPP should clearly identify the 
receiving waters and stormwater systems 
through which stormwater from your site 
could flow. Many states require planning 
for a specific storm event or storm events. 
These storm events are referred to by their 
recurrence interval and duration such as 
1-year, 6-hour storm or a 100-year, 24-hour 
storm. These events then translate into a 
specific rainfall amount depending on 
average conditions in your area. 

If your site’s stormwater flows into a 
municipal storm drain system, you should 
determine the ultimate destination of that 
system’s discharge. This may be obvious and 
easy to document. However, in some systems, 
you may have to consult with the local agency 


responsible for the storm drain system to 
determine the waterbody to which you are 
discharging. 

If your site’s stormwater runs off to areas 
not connected to the storm drain system, 
you should consider your land’s topography 
and then identify the waterbodies that it 
could reach. Many sites will discharge some 
stormwater to a storm drain system and some 
to other areas not connected to the system. 

If your site’s stormwater could potentially 
reach two or more waterbodies, note that 
in your SWPPP. Remember, stormwater can 
travel long distances over roads, parking lots, 
down slopes, across fields, and through storm 
sewers and drainage ditches. 

Describe Your Construction Project 

Your SWPPP should contain a brief 
description of the construction activity, 
including: 

• Project type or function (for example, 
low-density residential, shopping mall, 
highway) 

• Project location, including latitude and 
longitude 

• Estimated project start and end dates 

• Sequence and timing of activities that will 
disturb soils at the site 

• Size of the project 

• Estimated total area expected to be 
disturbed by excavation, grading, or other 
construction activities, including dedicated 
off-site borrow and fill areas 

• Percentage of impervious area before and 
after construction 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


11 




Construction Site Pollutants 

Areas of Consideration 

Primary 

Pollutant 

Other Pollutants 

Nutrients 

Heavy metals 

pH (acids & bases) 

Pesticides & herbicides 

Oil & grease 

Bacteria & viruses 

Trash, debris, solids 

Other toxic chemicals 

Sediment 

Clearing, grading, 
excavating, and 
unstabilized areas 








✓ 


Paving operations 










Concrete washout and 
waste 



✓ 







Structure construction/ 
painting/cleaning 









•/ 

Demolition and debris 
disposal 

V 









Dewatering operations 

S 









Drilling and blasting 
operations 

V 









Material delivery and 
storage 

S 

✓ 






✓ 


Material use during 
building process 


✓ 

S 






Y 

Solid waste (trash and 
debris) 









S 

Hazardous waste 






✓ 



V 

Contaminated spills 


✓ 







V 

Sanitary/septic waste 









V 

Vehicle/equipment fueling 
and maintenance 









s 

Vehicle/equipment use 
and storage 










Landscaping operations 

S 










• Runoff coefficient 1 before and after 
construction 

• Soil types 

• Construction site location and any nearby 
waters or wetlands 

• Describe and identify the location of 
other potential sources of stormwater 
contamination, such as asphalt and 
concrete plants, stucco operations, paint 
and concrete washout, and such 

Identify Pollutants and Pollution Sources 

Identify the pollutants and sources that are 
likely to be found on the site. The principle 
pollutant of concern, of course, is sediment. 
There are, however, other pollutants that 
may be found, usually in substantially 
smaller amounts, in stormwater runoff from 
construction sites. These can include nutrients, 
heavy metals, organic compounds, pesticides, 
oil and grease, bacteria and viruses, trash and 
debris, and other chemicals. After identifying 
the pollutants and sources, be as specific as 
possible in your SWPPP about the BMPs you 
will use to address them. The table at the left 
lists the sources of pollutants at construction 
sites, including sediment, the primary 
pollutant and other pollutants that may be 
present at construction sites. 



Figure 5. Make sure storm drain inlets 
are protected. 


1 The runoff coefficient is the partial amount of the total rainfall which will become runoff. Runoff coefficients generally range from 0.95 (highly impervious) to 0.05 (vegetated surface that 
generates little runoff). For more information on calculating the runoff coefficient for your site, see Appendix C. 


12 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 












































Non-Stormwater Discharges 

Most permits will require you to identify any 
non-stormwater discharges in your SWPPP. 
Certain non-stormwater discharges may be 
allowed under the terms and conditions of 
your permit, however, you should make every 
effort to eliminate these discharges where 
possible. You should identify these sources in 
your SWPPP and identify pollution prevention 
measures to ensure that pollutants are not 
introduced to these discharges and carried to 
nearby waterbodies. 

EPA’s CGP identifies these allowable non¬ 
stormwater discharges: discharges from 
fire-fighting activities, fire hydrant flushings, 
waters used to wash vehicles, buildings, 
and pavements where detergents are not 
used, water used to control dust, potable 
water [including uncontaminated water line 
flushings), uncontaminated air conditioning 
condensate, uncontaminated ground water 
or spring water, among others. The permit 
goes on to say that non-stormwater discharges 
should be eliminated or reduced to the extent 
feasible and that the SWPPP should identify 
and ensure the implementation of appropriate 
pollution prevention measures for these 
discharges. More discussion of pollution 
prevention measures for some of these non¬ 
stormwater sources can be found in Chapter 5. 

Permanent Stormwater Controls 
(Post-Construction) 

The topic of designing, installing, and 
maintaining permanent or post-construction 
stormwater controls, although a requirement, 
is beyond the scope of this SWPPP guide. A 
SWPPP compiled in support of coverage under 


EPA’s Construction General Permit, however, 
needs to include a description of all permanent 
stormwater controls that will be constructed 
along with the buildings, roads, parking lots, 
and other structures. You should incorporate 
sediment and erosion controls into your 
SWPPP for areas where permanent stormwater 
controls, such as wet ponds, swales, and 
bioretention cells are to be constructed. 

Effectively managing stormwater over the 
long-term—long after the actual construction 
process is over—is a significant challenge. 
Many communities (and a few states) have or 
are developing comprehensive requirements 
to better manage permanent (or post¬ 
construction) stormwater runoff. To be most 
effective, you should consider integrating your 
design process for your permanent stormwater 
controls into your overall design for your 
site. Planning for your permanent stormwater 
controls could affect your decisions about 
site design, location of buildings and other 
structures, grading, and preserving natural 
features. By preserving natural drainage 
patterns, trees, native vegetation, riparian 
buffers, and wetlands, you might need to 
construct fewer or smaller structural storm¬ 
water controls to cope with runoff from your 
site. Permanent stormwater controls should be 
designed with two important goals in mind: 

(1) reduction of the volume and velocity of 
runoff, and (2) reduction of the pollutants in 
the stormwater that does leave your site. 

Techniques, such as Low Impact Development, 
Better Site Design, or Conservation 
Development, which emphasize addressing 
stormwater where it falls, infiltrating it, 
preserving natural drainage patterns, and 


Take a Closer Look... 

Specimen Trees and Natural Vegetation 

Before a site plan is prepared, identify and 
clearly mark existing trees and vegetation you 
want to preserve. Some communities have tree 
preservation ordinances, and local extension 
service offices and foresters will often provide free 
advice on tree and plant preservation. Remember 
to notify all employees and subcontractors about 
trees and areas you intend to preserve and mark 
them clearly. 


What does this mean to me? 

Large trees and other native vegetation can represent significant value 
in the long term to property owners and the community at large. 

Many studies document that the presence of trees on residential and 
commercial sites provide many benefits including improved aesthetics, 
habitat for birds and other wildlife, and energy savings (shade) that 
ultimately enhance the economic value of the site. Trees also provide 
shade and act as windbreaks, which can reduce energy costs over the 
long term. By protecting existing trees, you can reduce landscaping 
costs and improve the appearance of a newly developed property. 
According to the National Arbor Day Foundation, trees around a home 
can increase its value by 15 percent or more. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


13 






preserving natural vegetation offer the best 
opportunity to protect nearby rivers, lakes, 
wetlands, and coastal waters. Incorporating 
these ideas and concepts into the design for 
your project before it is built also offers the 
opportunity to reduce capital infrastructure 
and long-term maintenance costs. 

At the neighborhood or even at the watershed 
scale, Smart Growth techniques can help 
us design neighborhoods that minimize 
impacts on water quality, reduce air pollution, 
and improve the general quality of life for 
residents. In the Resources list in Appendix 
D, you will find a list of suggestions on this 
topic, including how to incorporate Smart 
Growth and Low Impact Development 
techniques into the design of your site. 

B. Identify Approaches to Protect Natural 
Resources 

Preservation of natural areas, waterbodies, and 
open space has numerous economic, aesthetic, 
community, and environmental benefits. 
Preservation efforts also often increase the 
value of lots and homes and help to reduce 
overall expenditures on infrastructure. 
Specifically, these kinds of conservation efforts 
can help to significantly reduce the volume 
and velocity of stormwater runoff and the 
pollutants that may be carried with it. 




SWPPP Tip! 


Tree Preservation Resources 

For more on tree preservation, contact your 
local extension service office or forester. Also, 
American Forests has useful information and 
tools at their website, 
www.americanforests.org/ 
resources/urbanforests. The 
Center for Watershed Protection 
in cooperation with the U.S. 

Forest Service has developed 
a series of manuals on urban 
forestry. Part two, titled 
Conserving and Planting Trees 
at Development Sites will be of 
particular interest. You can find 
these manuals at www.cwp.org 



Protect Nearby Waters 

Your SWPPP should describe how you will pro¬ 
tect and preserve any streams, wetlands, ponds 
or other waterbodies that are on your property 
or immediately adjoining it. Riparian areas 
around headwater streams are especially im¬ 
portant to the overall health of the entire river 
system. Many states and communities have 
buffer or shoreline protection requirements to 
preserve sensitive areas around waterbodies. 

Many states apply special designations to 
high-value or high-quality waters. Check with 
your state water pollution control agency to 
determine if your project could discharge 
to outstanding or special protection waters 
(such as wetlands, or salmon and trout 
streams). You might be subject to additional 
requirements to protect these waterbodies. 

Wetland areas, including bogs, marshes, 
swamps, and prairie potholes may be found 
in areas adjacent to rivers, lakes, and coastal 
waters but may also be found in isolated 
places far from other surface waters. Many 
types of wetlands are protected under the 
Clean Water Act and construction activities 
in and around these areas may require an 
additional permit from the Army Corps of 
Engineers. Construction site operators should 
make every effort to preserve wetlands and 
must follow applicable local, state, and federal 
requirements before disturbing them or the 
areas around them. 

To ensure the protection of natural areas 
during the construction period, you should 
use a combination of techniques, including 
temporary fencing, signage, and educating 
staff and subcontractors. 

Assess Whether Your Project Impacts an 
Impaired Waterbody 

Under the Clean Water Act, states are required 
to determine if rivers, lakes, and other waters 
are meeting water quality standards. When 
a waterbody does not meet water quality 
standards because of one or more sources 
of pollution, the state lists the water as 
impaired. When a water is determined to be 
impaired, the state or EPA develops a plan for 
correcting the situation. This plan is called 
a Total Maximum Daily Load (TMDL). If 
stormwater from your project could reach an 
impaired water with or without an approved 
TMDL (either directly or indirectly through a 
municipal storm drain system), your permit 


14 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 






may include additional requirements to 
ensure that your stormwater discharges do 
not contribute to that impairment and your 
stormwater controls are consistent with plans 
to restore that waterbody. Your SWPPP should 
describe the specific actions you will take to 
comply with these permit requirements for 
impaired waters. 

You should determine, before you file for 
permit coverage, if the receiving waters for 
your project are impaired and if so, whether a 
TMDL has been developed for this waterbody. 
Visit EPA’s Enviromapper website (www. 
epa.gov/waters/enviromapper) or contact 
your state environmental agency for more 
information. 

Assess Whether You Have Endangered Plant or 
Animal Species in Your Area 

The federal Endangered Species Act protects 
endangered and threatened species and their 
critical habitat areas. (States and tribes may 
have their own endangered species laws.) In 
developing the assessment of your site, you 
should determine whether listed endangered 
species are on or near your property. Critical 
habitat areas are often designated to support 
the continued existence of listed species. You 
should also determine whether critical habitat 
areas have been designated in the vicinity 
of your project. Contact your local offices of 
the U.S. Fish and Wildlife Service (FWS), 
National Marine Fisheries Service (NMFS), 
or your state or tribal heritage centers. These 
organizations often maintain lists of federal 
and state listed endangered and threatened 
species on their Internet sites. For more 
information and to locate lists for your state, 
visit www.epa.gov/npdes/endangeredspecies 

Additionally, your state’s NPDES stormwater 
permit may specifically require that you 
address whether the activities and the 
stormwater discharged by your construction 
site have the potential to adversely affect 
threatened or endangered species or the 
critical habitat areas. You might need 
to conduct a biological investigation or 
assessment and document the results of the 
assessment in your SWPPP. The state may 
reference federal, state, or tribal endangered 
species protection laws or regulations. 

EPA’s Construction General Permit contains 
detailed procedures to assist construction site 
operators in determining the likely impact of 


their projects on any endangered species or 
critical habitat. Construction site operators in 
areas covered by EPA’s Construction General 
Permit are required to assess the impact of 
their activities and associated stormwater 
discharges on species and habitat in the 
“project area” which may extend beyond the 
site’s immediate footprint. 

Assess Whether You Have Historic Sites that 
Require Protection 

The National Historic Preservation Act, 
and any state, local and tribal historic 
preservation laws, apply to construction 
activities. As with endangered species, some 
permits may specifically require you to assess 
the potential impact of your stormwater 
discharges on historic properties. However, 
whether or not this is stated as a condition 
for permit coverage, the National Historic 
Preservation Act and any applicable state or 
tribal laws apply to you. Contact your State 
Historic Preservation Officer (www.ncshpo. 
org/stateinfolist/fulllist.htm) or your Tribal 
Historic Preservation Officer (grants.cr.nps. 
gov/thpo/tribaloffices.cfm). 

C. Develop Site Maps 

The final step in the site evaluation process 
is to document the results of your site 
assessment and your planned phases of 
construction activity on a detailed site map 
or maps. This includes developing site maps 
showing planned construction activities and 
stormwater practices for the various major 
stages of construction, protected areas, 
natural features, slopes, erodible soils, nearby 
waterbodies, permanent stormwater controls, 
and so on. You must keep your SWPPP and 
your site maps up-to-date to reflect changes at 
your site during the construction process. 

Location Maps 

A general location map is helpful to identify 
nearby, but not adjacent, waterbodies in 
proximity to other properties. You can use any 
easily available maps or mapping software to 
create a location map. 

Site Maps 

The detailed construction site maps should 
show the entire site and identify a number 
of features at the site related to construction 
activities and stormwater management 
practices. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


15 





PROPOSED MOUSING 
EXISTING HOUSING 
= STREET/ROAD 
CONTOURS 
UNLINED DRAINAGE 
EXISTING STORM DRAIN 
STORM WATER DRAINAGE 

STORM WATER DISCHARGE 
POINT 


SCALE: 1" - 150* 


Figure 6. Example site map. 


Map of undeveloped or existing site. For 
many sites, a map of the undeveloped or 
existing site, noting the features that you 
identified in Section A of this Chapter, will 
help you develop your SWPPP and identify 
current site features that you want to 
preserve. On this map note current drainage 
patterns, storm drains, slopes, soil types, 
waters and other natural features. Also note 
any existing structures, roads, utilities, and 
other features. 

Map or series of maps for construction plans. 

Site maps should show the construction 
activities and stormwater management 
practices for each major phase of construction 
(e.g., initial grading, infrastructure, 
construction, and stabilization). The site maps 
should legibly identify the following features: 

• Stormwater flow and discharges. Indicate 
flow direction(s) and approximate 
slopes after grading activities, as well as 
locations of discharges to surface waters or 
municipal storm drain systems. 

• Areas and features to be protected. Include 
wetlands, nearby streams, rivers, lakes, 
and coastal waters, mature trees and 
natural vegetation, steep slopes, highly 
erodible soils, etc. 

• Disturbed areas. Indicate locations and 
timing of soil disturbing activities (e.g. 
grading). Mark clearing limits. 

• BMPs. Identify locations of structural 
and non-structural BMPs identified in 


the SWPPP, as well as post-construction 
stormwater BMPs. 

• Areas of stabilization. Identify locations 
where stabilization practices are expected 
to occur. Mark areas where final 
stabilization has been accomplished. 

• Other areas and roads. Indicate locations 
of material, waste, borrow, or equipment 
storage. 

You should complete your site maps after 
reviewing Chapters 4 and 5 and any 
applicable BMP design manual to select 
appropriate BMPs for your site. 

Use Site Maps to Track Progress 

Develop and keep up-to-date site maps 
showing non-structural BMPs that change 
frequently in location as the work on a 
construction site progresses. Your permit 
requires that you keep your SWPPP up- 
to-date, so mark up the site map with the 
location of these BMPs. Indicate the current 
location of the following: 

• Portable toilets 

• Material storage areas 

• Vehicle and equipment fueling and 
maintenance areas 

• Concrete washouts 

• Paint and stucco washouts 

• Dumpsters or other trash and debris 
containers 

• Spill kits 

• Stockpiles 

• Any other non-structural non-stormwater 
management BMPs 

• Any temporarily removed structural BMPs 

• Any changes to the structural BMPs 

If a marked-up site map is too full to be easily 
read, you should date and fold it, put it in 
the SWPPP for documentation, and start a 
new one. That way, there is a good hard copy 
record of what has occurred on-site. 

Construction sites are dynamic. As conditions 
change at the construction site, such as the 
locations of BMPs, your SWPPP must reflect 
those changes. 


16 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 




































Chapter 4: SWPPP Development—Selecting 
Erosion and Sediment Control BMPs 

This document is not intended as an engineering or design manual on BMPs. The 
engineer or other qualified person that develops the details of your sediment and 
erosion control plan should be using the appropriate state or local specifications. 

The descriptions below provide a kind of checklist of the things to look for and some 
helpful installation and maintenance hints. 


► This chapter presents 
a brief discussion of 
erosion and sediment 
control principles and 
a discussion of some 
commonly used BMPs. 


Erosion and sediment controls are the structural and non-structural practices used 
during the construction process to keep sediment in place (erosion control) and to 
capture any sediment that is moved by stormwater before it leaves the site (sediment 
control). Erosion controls—keeping soil where it is—are the heart of any effective 
SWPPP. Your SWPPP should rely on erosion controls as the primary means of 
preventing stormwater pollution. Sediment controls provide a necessary second line 
of defense to properly designed and installed erosion controls. 

The suite of BMPs that you include in your SWPPP should reflect the specific condi¬ 
tions at the site. The information that you collected in the previous steps should help 
you select the appropriate BMPs for your site. 

An effective SWPPP includes a combination 
or suite of BMPs that are designed to work 


together. 

Ten Keys to Effective Erosion and 
Sediment Control (ESC) 

The ultimate goal of any SWPPP is to protect 
rivers, lakes, wetlands, and coastal waters 
that could be affected by your construction 
project. The following principles and tips 
should help you build an effective SWPPP. 
Keep in mind that there are many BMP 
options available to you. We have selected 
a few common BMPs to help illustrate the 
principles discussed in this chapter. 


Take a Closer Look... 

BMPs in Combination 

BMPs work much better when they are used in 
combination. For instance, a silt fence should not be 
used alone to address a bare slope. An erosion control 
BMP should be used to stabilize the slope, and the silt 
fence should serve as the backup BMP. 


Erosion Control (keeping the dirt in place) and 
Minimizing the Impact of Construction 

1. Minimize disturbed area and protect natural features and soil 

2. Phase construction activity 

3. Control stormwater flowing onto and through the project 

4. Stabilize soils promptly 

5. Protect slopes 

Sediment Controls (the second line of defense) 

6. Protect storm drain inlets 

7. Establish perimeter controls 

8. Retain sediment on-site and control dewatering practices 

9. Establish stabilized construction exits 

10. Inspect and maintain controls 


What does this mean to me? 

Wherever possible, rely on erosion controls to keep sediment 
in place. Back up those erosion controls with sediment 
controls to ensure that sediment doesn’t leave your site. 
Continually evaluate your BMPs. Are they performing 
well? Could the addition of a supplemental BMP improve 
performance? Should you replace a BMP with another one 
that might work better? Using BMPs in series also gives you 
some protection in case one BMP should fail. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


17 





I 


■■■■■■■■■■■■■■■■■■■I 


Erosion Control and Minimizing the Impact of 
Construction 

ESC Principle 1: Minimize disturbed area 
and protect natural features and soil. As you 

put together your SWPPP, carefully consider 
the natural features of the site that you 
assessed in Chapter 3. By carefully delineating 
and controlling the area that will be disturbed 
by grading or construction activities, you can 
greatly reduce the potential for soil erosion 
and stormwater pollution problems. Limit 
disturbed areas to only those necessary for the 
construction of your project. Natural vegetation 
is your best and cheapest erosion control BMP. 

Protecting and 
preserving topsoil 
is also a good 
BMP. Removing 
topsoil exposes 
underlying layers 
that are often 
more prone to 
erosion and have 
less infiltration 



Figure 7. Protect vegetated buffers by using silt fence 
or other sediment controls. 


capacity. Keeping 
topsoil in place 
preserves the 
natural structure 
of the soils 
and aids the 
infiltration of 
stormwater. 


ESC Principle 2: Phase construction 
activity. Another technique for minimizing 
the duration of exposed soil is phasing. By 
scheduling or sequencing your construction 
work and concentrating it in certain areas, 
you can minimize the amount of soil that is 
exposed to the elements at any given time. 
Limiting the area of disturbance to places 
where construction activities are underway 
and stabilizing them as quickly as possible 
can be one of your most effective BMPs. 


ESC Principle 3: Control stormwater 
flowing onto and through your project. Plan 
for any potential stormwater flows coming 
onto the project area from upstream locations, 
and divert (and slow) flows to prevent 
erosion. Likewise, the volume and velocity of 
on-site stormwater runoff should be controlled 
to minimize soil erosion. 

Example BMP: Diversion Ditches or Berms 

Description: Diversion ditches or berms 
direct runoff away from unprotected 
slopes and may also direct sediment-laden 
runoff to a sediment-trapping structure. 

A diversion ditch can be located at the 
upslope side of a construction site to prevent 
surface runoff from entering the disturbed 
area. Ditches or berms on slopes need to be 
designed for erosive velocities. Also, ensure 
that the diverted water is released through a 
stable outlet and does not cause downslope 
or downstream erosion or flooding. 

Installation Tips: 

• Divert run-on and runoff away from 
disturbed areas 

• Ensure that the diversion is protected 
from erosion, using vegetation, 
geotextiles, or other appropriate BMPs 

• Divert sediment-laden water to a 
sediment-trapping structure 

• Use practices that encourage infiltration 
of stormwater runoff wherever possible 

Maintenance: 

• Inspect diversions and berms, including 
any outlets, regularly and after each 
rainfall 

• Remove any accumulated sediment 



Figure 8. Illustration of a construction berm to divert 
stormwater away from the disturbed construction 
area. 


18 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 













ESC Principle 4: Stabilize soils promptly. 

Where construction activities have 
temporarily or permanently ceased, you 
should stabilize exposed soils to minimize 
erosion. You should have stabilization 
measures in place after grading activities have 
ceased (many permits require stabilization 
within a specified time frame). You can 
provide either temporary or permanent 
cover to protect exposed soils. Temporary 
measures are necessary when an area of a site 
is disturbed but where activities in that area 
are not completed or until permanent BMPs 
are established. Topsoil stockpiles should also 
be protected to minimize any erosion from 
these areas. Temporary-cover BMPs include 
temporary seeding, mulches, matrices, 
blankets and mats, and the use of soil binders 
(there may be additional state and local 
requirements for the use of chemical-based 
soil binders). Permanent-cover BMPs include 
permanent seeding and planting, sodding, 
channel stabilization, and vegetative buffer 
strips. Silt fence and other sediment control 
measures are not stabilization measures. 


SWPPP Tip! 


Final Stabilization 

Once construction activity in an area is 
completed and the area is stabilized (typically 
by achieving 70 percent permanent vegetative 
cover), you can mark this area on your SWPPP 
and discontinue inspections in that area. By 
bringing areas of your site to final stabilization, 
you can reduce your workload associated with 
maintaining and inspecting BMPs. For more 
information on final stabilization, see Chapter 9. 

Example BMP: Temporary Seeding 

Description: Temporarily seeding an area 
to establish vegetative cover is one of the 
most effective, and least expensive, methods 
of reducing erosion. This approach, as a 
single BMP, might not be appropriate on 
steep slopes, when vegetation cannot be 
established quickly enough to control erosion 
during a storm event, or when additional 
activities might occur soon in the area. 

Installation Tips: 

• Seed and mulch area (the mulch 

provides temporary erosion protection by 
protecting the soil surface, moderating 
temperature, and retaining moisture 
while seeds germinate and grow) 


• Water regularly, if needed, to ensure 
quick growth 

• Maintain backup BMPs, such as silt fence 
or settling ponds 


SWPPP Tip! 


Wind Control BMPs 

In areas where dust control is an issue, your 
SWPPP should include BMPs for wind-erosion 
control. These consist of mulching, wet 
suppression (watering), and other practices. 

ESC Principle 5: Protect slopes. Protect 
all slopes with appropriate erosion controls. 
Steeper slopes, slopes with highly erodible 
soils, or long slopes require a more complex 
combination of controls. Erosion control 
blankets, bonded fiber matrices, or turf 
reinforcement mats are very effective options. 
Silt fence or fiber rolls may also be used to 
help control erosion on moderate slopes and 
should be installed on level contours spaced 
at 10- to 20-foot intervals. You can also 
use diversion channels and berms to keep 
stormwater off slopes. 

Example BMP: Rolled erosion control products 
Description: Erosion control products 
include mats, geotextiles, and erosion 
control blankets and products that provide 
temporary stabilization and help to 
establish vegetation on disturbed soils. 

Such products help control erosion and help 
establish vegetation and are often used on 
slopes, channels, or stream banks. 



Figure 9. Illustration of erosion control blankets 
installed on slope. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


19 













Installation Tips: 

• Use rolled erosion-control products on 
slopes steeper than 3 to 1 (horizontal to 
vertical) and in swales or long channels 



Figure 10. Illustration of a fiber roll installation 
along a slope. 


Trench the top 
of the blanket 
into the ground 
to prevent runoff 
from flowing 
under the blanket 

Overlap the lower 
end of the top mat 
over the top of the 
downslope mat to 
ensure that runoff 
stays on top of the 
blankets and mats 

Staple blankets 
and mats 
according to 
specifications 


Maintenance: 

• Periodically inspect for signs of erosion 
or failure 


• Repair the blanket or mat if necessary 

• Continue inspections until vegetation 
is established at the level required to 
qualify as final stabilization 


Example BMP: Storm Drain Inlet Protection 

Description: Storm drain inlet protection 
prevents sediment from entering a storm 
drain by surrounding or covering the inlet 
with a filtering material. Several types 
of filters are commonly used for inlet 
protection: silt fence, rock-filled bags, or 
block and gravel. The type of filter used 
depends on the inlet type (for example, curb 
inlet, drop inlet), slope, and volume of flow. 
Many different commercial inlet filters are 
also available. Some commercial inlet filters 
are placed in front of or on top of an inlet, 
while others are placed inside the inlet 
under the grate. 



Runoff 


Settled 

Sediment 


Figure 11. Illustration of a storm drain inlet with 
rock-filled bags filtering stormwater. 


ESC Principle 6: Protect storm drain 
inlets. Protect all inlets that could receive 
stormwater from the project until final 
stabilization of the site has been achieved. 
Install inlet protection before soil-disturbing 
activities begin. Maintenance throughout 
the construction process is important. Upon 
completion of the project, storm drain inlet 
protection is one of the temporary BMPs 
that should be removed. Storm drain inlet 
protection should be used not only for storm 
drains within the active construction project, 
but also for storm drains outside the project 
area that might receive stormwater discharges 
from the project. If there are storm drains on 
private property that could receive stormwater 
runoff from your project, coordinate with the 
owners of that property to ensure proper inlet 
protection. 


Installation Tips: 

• Install inlet protection as soon as storm 
drain inlets are installed and before 
land-disturbance activities begin in areas 
with existing storm drain systems 

• Protect all inlets that could receive 
stormwater from your construction 
project 

• Use in conjunction with other erosion 
prevention and sediment control BMPs— 
remember, inlet protection is a secondary 
BMP! 

• Design your inlet protection to handle 
the volume of water from the area being 
drained. Ensure that the design is sized 
appropriately. 

Maintenance: 

• Inspect inlets frequently and after each 
rainfall 


20 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 







• Remove accumulated sediment from 
around the device and check and remove 
any sediment that might have entered 
the inlet 

• Replace or repair the inlet protection if it 
becomes damaged 

• Sweep streets, sidewalks, and other 
paved areas regularly 


SWPPP Tip! 


Storm drain inlet protection should never be 
used as a primary BMP! Use erosion control 
techniques such as hydromulching or erosion- 
control blankets to prevent erosion. Use inlet 
protection and other sediment control BMPs as 
a backup or last line of defense. 


ESC Principle 7: Establish perimeter 
controls. Maintain natural areas and 
supplement them with silt fence and fiber 
rolls around the perimeter of your site to 
help prevent soil erosion and stop sediment 
from leaving the site. Install controls on the 
downslope perimeter of your project (it is 
often unnecessary to surround the entire 
site with silt fence). Sediment barriers can 
be used to protect stream buffers, riparian 



Figure 12. Illustration of proper techniques to use 
in installing silt fence. 


areas, wetlands, or other waterways. They are 
effective only in small areas and should not 
be used in areas of concentrated flow. 

Example BMP: Silt Fence and Fiber Rolls 

Description: A silt fence is a temporary 
sediment barrier consisting of a geotextile 
attached to supporting posts and trenched 
into the ground. Silt fencing is intended to 
retain sediment that has been dislodged by 
stormwater. It is designed only for runoff 
from small areas and is not intended to 
handle flows from large slopes or in areas 
of concentrated flow. Fiber rolls serve the 
same purpose and consist of an open mesh 
tubular sleeve filled with a fibrous material 
which traps sediment. Fiber rolls are 
generally staked to the ground. 

Installation Tips: 

DO: 

• Use silt fence or fiber rolls as perimeter 
controls, particularly at the lower or 
down slope edge of a disturbed area 

• Leave space for maintenance between toe 
of slope and silt fence or roll 

• Trench in the silt fence on the uphill side 
(6 inches deep by 6 inches wide) 

• Install stakes on the downhill side of the 
fence or roll 

• Curve the end of the silt fence or fiber 
roll up-gradient to help it contain runoff 

DON’T: 

• Install a silt fence or fiber rolls in ditches, 
channels, or areas of concentrated flow 

• Install it running up and down a slope or 
hill 

• Use silt fencing or fiber rolls alone in 
areas that drain more than a quarter-acre 
per 100 feet of fence 

Maintenance: 

• Remove sediment when it reaches one- 
third of the height of the fence or one- 
half the height of the fiber roll 

• Replace the silt fence or roll where it is 
worn, torn, or otherwise damaged 

• Retrench or replace any silt fence or 
roll that is not properly anchored to the 
ground 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


21 








ESC Principle 8: Retain sediment on-site 
and control dewatering practices. Sediment 
barriers described in ESC Principle 7 can 
trap sediment from small areas, but when 
sediment retention from a larger area 
is required, consider using a temporary 
sediment trap or sediment basin. These 
practices detain sediment-laden runoff for a 
period of time, allowing sediment to settle 
before the runoff is discharged. Proper design 
and maintenance are essential to ensure that 
these practices are effective. 


You should 
use a sediment 
basin for 
common 
drainage 
locations that 
serve an area 
with 10 or 
more acres 
disturbed 
at any one 
time. The 
basin should 
be designed 
to provide 
storage for 

the volume of runoff from the drainage area 
for at least a 2-year, 24-hour storm (or 3,600 
cubic feet of storage per acre drained, which 
is enough to contain 1 inch of runoff, if the 
2-year, 24-hour calculation has not been 
performed). Check your permit for exact basin 
sizing requirements. Sediment basins should 
be located at low-lying areas of the site and 
on the down-gradient side of bare soil areas 
where flows converge. Do not put sediment 
traps or basins in or immediately adjacent to 
flowing streams or other waterways. 

Where a large sediment basin is not practical, 
use smaller sediment basins or sediment 
traps (or both) where feasible. At a minimum, 
use silt fences, vegetative buffer strips, or 
equivalent sediment controls for all down- 
gradient boundaries (and for those side-slope 
boundaries deemed appropriate for individual 
site conditions). 

Dewatering practices are used to remove 
ground water or accumulated rain water from 
excavated areas. Pump muddy water from 
these areas to a temporary or permanent 
sedimentation basin or to an area completely 
enclosed by silt fence in a flat vegetated area 
where discharges can infiltrate into the ground. 




trap and basin 



Length = 2x width or more Jfc 'J 



J ^h 



Width. 

I 

✓ seeded 


✓ stable outlet 

✓ maintained 

'MS? 


Figure 13. Illustration of a sediment basin. 


Never discharge muddy water into storm 
drains, streams, lakes, or wetlands unless the 
sediment has been removed before discharge. 

Keep in mind that some states and local 
jurisdictions require a separate permit for 
dewatering activities at a site. 

ESC Principle 9: Establish stabilized con¬ 
struction exits. Vehicles entering and leaving 
the site have the potential to track significant 
amounts of sediment onto streets. Identify 
and clearly mark one or two locations where 
vehicles will enter and exit the site and focus 
stabilizing measures at those locations. 
Construction entrances are commonly made 
from large crushed rock. They can be further 
stabilized using stone pads or concrete. Also, 
steel wash racks and a hose-down system 
will remove even more mud and debris from 
vehicle tires. Divert runoff from wash areas to 
a sediment trap or basin. No system is perfect, 
so sweeping the street regularly completes 
this BMP. 

Example BMP: Stabilized Construction Exit 

Description: A rock construction exit can 
reduce the amount of mud transported onto 
paved roads by vehicles. The construction 
exit does this by removing mud from 
vehicle tires before the vehicle enters a 
public road. 



Figure 14. Illustration of a stabilized construction 
exit. 


22 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 











You might also want to install a wheel 
wash when mud is especially difficult to 
remove or space doesn’t allow sufficient 
tire revolutions (four or five are needed) 
before exiting the site. Direct wash water to 
a suitable settling area—do not discharge 
wash water to a stream or storm drain! 

Installation tips: 

• Ensure that the exit is at least 50 feet 
long (generally, the length of two dump 
trucks) and graded so runoff does not 
enter the adjacent street 

• Place a geotextile fabric under a layer of 
aggregate at least 6-12 inches thick. The 
stones or aggregate should be 3-6 inches 
in diameter 

• Train employees and subcontractors to 
use the designated construction exits. 
Empower your employees to provide 
directions to subcontractors and others 
that are not on the site every day 

Maintenance: 

• Replenish or replace aggregate if it 
becomes clogged with sediment 

• Sweep the street regularly 

ESC Principle 10: Inspect and maintain 
controls . Inspection and maintenance is just 
as important as proper planning, design, and 
installation of controls. Without adequate 
maintenance, erosion and sediment controls 
will quickly fail, sometimes after just one 
rainfall, and cause significant water quality 
problems and potential violations of the 
NPDES construction general permit. Your 
permit likely requires you to maintain your 
BMPs at all times. To do this effectively, 
you should establish an inspection and 
maintenance approach or strategy that 
includes both regular and spot inspections. 
Inspecting both prior to predicted storm 
events and after will help ensure that controls 
are working effectively. Perform maintenance 
or corrective action as soon as problems are 
noted. Inspection and maintenance of BMPs 
are addressed in more detail in Chapter 6. 


Other Sediment and Erosion Control 
Techniques 

As mentioned at the beginning of this 
chapter, there are many other erosion and 
sediment control techniques that can be used 
effectively. The BMPs highlighted in this 
chapter are among those more commonly 
used and highlight many general erosion and 
sediment control principles for which other 
BMPs may be used effectively. Check to see if 
your state or local government has developed 
a BMP design manual for detailed information 
on any BMP you are considering. Appendix D 
lists several good BMP design manuals. You 
can also find out more about various BMPs 
by visiting EPA’s Menu of BMPs at www.epa. 
gov/npdes/menuofbmps 

The following BMPs are also commonly used 
at construction sites. 

Erosion control measures: 

• Surface roughening, trackwalking, 
scarifying, sheepsfoot rolling, imprinting 

• Soil bioengineering techniques (e.g., live 
staking, fascines, brush wattles) 

• Composting 

• Sodding 

Sediment control and runoff management 
measures: 

• Gravel bag barrier 

• Compost berm 

• Rock or brush filters 

• Baffles or skimmers in sediment basins to 
increase effectiveness 

• Lowering soil levels near streets and 
sidewalks to prevent runoff 

• Level spreaders 

• Energy dissipaters 

• Check dams 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


23 




Chapter 5: SWPPP Development—Selecting Good 
Housekeeping BMPs 


Six Key Pollution Prevention Principles for Good Housekeeping 

Construction projects generate large amounts of building-related waste, which can 
end up polluting stormwater runoff if not properly managed. The suite of BMPs 
that are described in your SWPPP must include pollution prevention (P2) or good 
housekeeping practices that are designed to prevent contamination of stormwater 
from a wide range of materials and wastes at your site. The six principles described 
below are designed to help you identify the pollution prevention practices that should 
be described in your SWPPP and implemented at your site. 

1. Provide for waste management 

2. Establish proper building material staging areas 

3. Designate paint and concrete washout areas 

4. Establish proper equipment/vehicle fueling and maintenance practices 

5. Control equipment/vehicle washing and allowable non-stormwater discharges 

6. Develop a spill prevention and response plan 

P2 Principle 1: Provide for waste management. Design proper management 
procedures and practices to prevent or reduce the discharge of pollutants to stormwater 
from solid or liquid wastes that will be generated at your site. Practices such as trash 
disposal, recycling, proper material handling, and cleanup measures can reduce the 
potential for stormwater runoff to pick up construction site wastes and discharge them 
to surface waters. 


► This chapter presents 
a brief discussion of 
good housekeeping 
principles to consider 
to ensure your 
construction site 
does not contaminate 
stormwater runoff. 

As noted in Chapter 3, 
sediment is the 
principal pollutant of 
concern in stormwater 
discharges from 
construction sites. But, 
EPA’s CGP and many 
state construction 
general permits 
require that the 
SWPPP describe good 
housekeeping measures 
for other pollutants 
that might be found 
on construction sites. 
This chapter discusses 
these measures. 



Figure 15. Illustration showing construction materials 
with secondary containment and overhead cover to 
prevent stormwater contamination. 


Provide convenient, well-maintained, 
and properly located toilet facilities. 
Provide for regular inspections, service, 
and disposal. Locate toilet facilities 
away from storm drain inlets and 
waterways to prevent accidental spills 
and contamination of stormwater. Treat 
or dispose of sanitary and septic waste in 
accordance with state or local regulations. 

Proper material use, storage, waste 
disposal, and training of employees and 
subcontractors can prevent or reduce 
the discharge of hazardous and toxic 
wastes to stormwater. Implement a 
comprehensive set of waste-management 
practices for hazardous or toxic 
materials, such as paints, solvents, 
petroleum products, pesticides, wood 
preservatives, acids, roofing tar, and 
other materials. Practices should include 
storage, handling, inventory, and cleanup 
procedures, in case of spills (see the 
following P2 principles). 


24 


Developing Your Stormwater Pollution Prevention Plan-. A Guide for Construction Sites 











Waste Management Checklist 

Solid or Construction Waste 

s Designate trash and bulk waste-collection areas on-site 
s Recycle materials whenever possible (e.g., paper, wood, concrete, oil) 

^ Segregate and provide proper disposal options for hazardous material wastes 
s Clean up litter and debris from the construction site daily 

^ Locate waste-collection areas away from streets, gutters, watercourses, and storm drains. Waste-collection areas (dump¬ 
sters, and such) are often best located near construction site entrances to minimize traffic on disturbed soils. Consider 
secondary containment around waste collection areas to further minimize the likelihood of contaminated discharges. 

Sanitary and Septic Waste 

s Provide restroom facilities on-site 

s Maintain clean restroom facilities and empty porta-johns regularly 
s Provide secondary containment pans under porta-johns, where possible 
s Provide tie-downs or stake downs for porta-johns in areas of high winds 
s Educate employees, subcontractors, and suppliers on locations of facilities 
s Do not discharge or bury wastewater at the construction site 
s Inspect facilities for leaks, repair or replace immediately 
Hazardous Materials and Wastes 

s Develop and implement employee and subcontractor education, as needed, on hazardous and toxic waste handling, stor¬ 
age, disposal, and cleanup 

s Designate hazardous waste-collection areas on-site 
s Place all hazardous and toxic material wastes in secondary containment 

s Hazardous waste containers should be inspected to ensure that all containers are labeled properly and that no 
leaks are present 


P2 Principle 2: Establish proper building 
material handling and staging areas. 

Your SWPPP should include comprehensive 
handling and management procedures for 
building materials, especially those that 
are hazardous or toxic. Paints, solvents, 
pesticides, fuels and oils, other hazardous 
materials or any building materials that have 
the potential to contaminate stormwater 
should be stored indoors or under cover 
whenever possible or in areas with secondary 
containment. Secondary containment 
prevents a spill from spreading across the 
site and include dikes, berms, curbing, or 
other containment methods. Secondary 
containment techniques should also ensure 
the protection of ground water. Designate 
staging areas for activities such as fueling 
vehicles, mixing paints, plaster, mortar, and 
so on. Designated staging areas will help 
you to monitor the use of materials and to 
clean up any spills. Training employees and 
subcontractors is essential to the success of 
this pollution prevention principle. 


SWPPP Tip! 


Material Staging Area Measures 

Your SWPPP should include procedures for storing materials that can 
contribute pollutants to stormwater. Consider the following: 

• Train employees and subcontractors in proper handling and 
storage practices 

• Designate site areas for storage. Provide storage in accordance 
with secondary containment regulations and provide cover 

for hazardous materials when necessary. Ensure that storage 
containers are regularly inspected for leaks, corrosion, support or 
foundation failure, or any other signs of deterioration and tested 
for soundness 

• Reuse and recycle construction materials when possible 


P2 Principle 3: Designate washout areas. 

Concrete contractors should be encouraged, 
where possible, to use the washout facilities 
at their own plants or dispatch facilities. 

If it is necessary to provide for concrete 
washout areas on-site, designate specific 
washout areas and design facilities to handle 
anticipated washout water. Washout areas 
should also be provided for paint and stucco 
operations. Because washout areas can be 
a source of pollutants from leaks or spills, 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


25 



EPA recommends that you locate them at 
least 50 yards away from storm drains and 
watercourses whenever possible. 

Several companies rent or sell prefabricated 
washout containers, and some provide 
disposal of waste solids and liquids along 
with the containers. These prefabricated 
containers are sturdy and provide a more 
reliable option for preventing leaks and 
spills of wash water than self-constructed 
washouts. Alternatively, you can construct 
your own washout area, either by digging a 
pit and lining it with 10 mil plastic sheeting or 
creating an aboveground structure from straw 
bales or sandbags with a plastic liner. If you 
create your own structure, you should inspect 
it daily for leaks or tears in the plastic because 
these structures are prone to failure. 

Regular inspection and maintenance are 
important for the success of this BMP. Both 
self-constructed and prefabricated washout 
containers can fill up quickly when concrete, 
paint, and stucco work are occurring on large 
portions of the site. You should also inspect 
for evidence that contractors are using the 
washout areas and not dumping materials onto 
the ground or into drainage facilities. If the 
washout areas are not being used regularly, 
consider posting additional signage, relocating 
the facilities to more convenient locations, or 
providing training to workers and contractors. 


SWPPP Tip! 


Washout Area Measures 

When concrete, paint, or stucco is part of the construction process, 
consider these practices which will help prevent contamination 
of stormwater, include the locations of these areas and your 
maintenance and inspection procedures in your SWPPP. 

• Do not washout concrete trucks or equipment into storm drains, 
streets, gutters, uncontained areas, or streams 

• Establish washout areas and advertise their locations with signs 

• Provide adequate containment for the amount of wash water that 
will be used 

• Inspect washout structures daily to detect leaks or tears and to 
identify when materials need to be removed 

• Dispose of materials properly. The preferred method is to allow 
the water to evaporate and to recycle the hardened concrete. Full 
service companies may provide dewatering services and should 
dispose of wastewater properly. Concrete wash water can be highly 
polluted. It should not be discharged to any surface water, storm 
sewer system, or allowed to infiltrate into the ground. It should not 
be discharged to a sanitary sewer system without first receiving 
written permission from the system operator 


P2 Principle 4: Establish proper equipment/ 
vehicle fueling and maintenance practices. 

Performing equipment/vehicle fueling and 
maintenance at an off-site facility is preferred 
over performing these activities on the site, 
particularly for road vehicles (e.g., trucks, 
vans). For grading and excavating equipment, 
this is usually not possible or desirable. Create 
an on-site fueling and maintenance area that is 
clean and dry. The on-site fueling area should 
have a spill kit, and staff should know how 
to use it. If possible, conduct vehicle fueling 
and maintenance activities in a covered area; 
outdoor vehicle fueling and maintenance is a 
potentially significant source of stormwater 
pollution. Significant maintenance on vehicles 
and equipment should be conducted off-site. 


SWPPP Tip! 


Equipment/Vehicle Fueling and 
Maintenance Measures 

Consider the following practices to help prevent 
the discharge of pollutants to stormwater from 
equipment/vehicle fueling and maintenance. 
Include the locations of these areas and your 
inspection and maintenance procedures in your 
SWPPP. 

• Train employees and subcontractors in proper 
fueling procedures (stay with vehicles during 
fueling, proper use of pumps, emergency shut¬ 
off valves, and such) 

• Inspect on-site vehicles and equipment daily 
for leaks, equipment damage, and other service 
problems 

• Clearly designate vehicle/equipment service 
areas away from drainage facilities and water¬ 
courses to prevent stormwater run-on and runoff 

• Use drip pans, drip cloths, or absorbent pads 
when replacing spent fluids 

• Collect all spent fluids, store in appropriate 
labeled containers in the proper storage areas, 
and recycle fluids whenever possible 


P2 Principle 5: Control equipment/vehicle 
washing and allowable non-stormwater 
discharges. Environmentally friendly wash¬ 
ing practices can be practiced at every con¬ 
struction site to prevent contamination of 
surface and ground water from wash water. 
Procedures and practices include using off-site 
facilities; washing in designated, contained 
areas only; eliminating discharges to the 
storm drain by infiltrating the wash water 
or routing to the sanitary sewer; and train¬ 
ing employees and subcontractors in proper 
cleaning procedures. 


26 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 




Take a Closer Look... 


Non-Stormwater Runoff 

A construction site might have sources of runoff that are not 
generated by stormwater. These non-stormwater discharges 
include fire hydrant flushing, vehicle or equipment wash water (no 
detergents!), water used to control dust, and landscape irrigation. 


What does this mean to me? 

Take steps to infiltrate these sources of uncontami¬ 
nated water into the ground. You can also route these 
sources of water to sediment ponds or detention 
basins or otherwise treat them with appropriate BMPs. 


W SWPPP Tip! 


Equipment/Vehicle Washing Measures 

The following equipment/vehicle washing 

measures will help prevent stormwater pollution. 

Include the location of your washing facilities and 

your inspection and maintenance procedures in 

your SWPPP. 

• Educate employees and subcontractors on 
proper washing procedures 

• Clearly mark the washing areas and inform 
workers that all washing must occur in this area 

• Contain wash water and treat and infiltrate it 
whenever possible 

• Use high-pressure water spray at vehicle 
washing facilities without any detergents 
because water can remove most dirt adequately 

• Do not conduct any other activities, such as 
vehicle repairs, in the wash area 


requirements and ensure that clear and concise 
spill cleanup procedures are provided and 
posted for areas in which spills may potentially 
occur. When developing a spill prevention plan, 
include, at a minimum, the following: 

• Note the locations of chemical storage areas, 
storm drains, tributary drainage areas, 
surface waterbodies on or near the site, and 
measures to stop spills from leaving the site 

• Specify how to notify appropriate authorities, 
such as police and fire departments, 
hospitals, or municipal sewage treatment 
facilities to request assistance 

• Describe the procedures for immediate 
cleanup of spills and proper disposal 

• Identify personnel responsible for 
implementing the plan in the event of a spill 


P2 Principle 6: Develop a spill prevention 
and response plan. Most state and EPA 
construction general permits require the 
preparation of spill prevention and response 
plans. Generally, these plans can be included 
or incorporated into your SWPPP. The plan 
should clearly identify ways to reduce the 
chance of spills, stop the source of spills, 
contain and clean up spills, dispose of 
materials contaminated by spills, and train 
personnel responsible for spill prevention 
and response. The plan should also specify 
material handling procedures and storage 


¥ SWPPP Tip! 


Spill Prevention Measures 

Additional spill prevention measures that will help prevent spills and 

leaks include the following: 

• Describe and list all types of equipment to be used to adequately 
clean up the spill 

• Provide proper handling and safety procedures for each type of 
waste 

• Establish an education program for employees and subcontractors 
on the potential hazards to humans and the environment from spills 
and leaks 

• Update the spill prevention plan and clean up materials as changes 
occur to the types of chemicals stored and used at the facility 


Take a Closer Look... 

Spill Prevention, Control and Countermeasure (SPCC) Plan 

Construction sites may be subject to 40 CFR Part 112 regulations that require the preparation and implementation of a SPCC 
Plan to prevent oil spills from aboveground and underground storage tanks. Your facility is subject to this rule if you are a 
nontransportation-related facility that: 

• Has a total storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons 


and 

• Could reasonably be expected to discharge oil in quantities that 
may be harmful to navigable waters of the United States and 
adjoining shorelines 

Furthermore, if your facility is subject to 40 CFR Part 112, your 
SWPPP should reference the SPCC Plan. To find out more about SPCC 
Plans, see EPA’s website on SPPC at www.epa.gov/oilspill/spcc.htm 


What does this mean to me? 

Reporting Oil Spills 

In the event of an oil spill, you should contact the 
National Response Center toll free at 1-800-424- 
8802 for assistance, or for more details, visit their 
website: www.nrc.uscg.mil/nrchp.html 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


27 









mmm 


Chapter 6: SWPPP Development—Inspections, 
Maintenance, and Recordkeeping 


A. Describe Your Plans and Procedures for Inspecting BMPs 

Earlier discussions in this manual pointed out that the effectiveness of erosion and 
sediment control BMPs and good housekeeping and pollution prevention measures 
depend on consistent and continual inspection and maintenance. This step focuses on 
developing a plan for BMP inspection and maintenance to ensure that a schedule and 
procedures are in place. 

Inspections 

Your responsibility does not stop after BMPs are installed. Your BMPs must be maintained 
in good working order at all times. Further, your permit requires that you conduct regular 
inspections and document the findings of those inspections in your SWPPP. 


► This chapter 
describes the 
inspection and 
maintenance 
procedures your 
SWPPP should 
include, as well 
as recordkeeping 
requirements. 


Your construction general permit describes the minimum frequency of inspections, 
which is typically weekly or bi-weekly and after each rainfall event exceeding one- 
half inch. To meet the requirement to maintain all BMPs in good working order, EPA 
recommends that you develop an inspection schedule that goes beyond these minimums 
and is customized for your site and the conditions affecting it. 


In developing your inspection schedule consider the following: 








Consider using spot inspections. You may want to inspect certain parts of your 
site more frequently or even daily. Target places that need extra attention, such as 
areas around construction site entrances, check nearby streets for dirt, check inlet 
protection, and so on. 


Consider using informal inspections. Your 
permit outlines the minimum requirements 
for formal inspections that must be 
documented and included in your SWPPP. 
You can also add informal inspections that 
wouldn’t require documentation, unless 
of course, a problem is identified. Always 
document any problems you find and those 
that are identified by staff. 

Consider adding inspections before or even 
during rain events. Many permits require 
inspections of BMPs after rain events. You 
should consider adding inspections before 
or during predicted rain events. Consult a 
local weather source and initiate inspections 
before predicted storm events as a way to 
ensure that controls are operational. 




SWPPP Tip! 


Inspection Guide 

The State of Minnesota has 
developed a Stormwater 
Construction Inspection Guide to 
assist municipal site inspectors 
in procedures for conducting 
a compliance inspection at 
construction sites. This guide can 
also be useful for construction 
operators conducting self¬ 
inspections. Available at 
www.pca.state.mn.us/water/ 
stormwater/stormwatr-c.html 



• Train staff and subcontractors. Use your staff and subcontractors to help identify any 
potential problems with your BMPs. Again, document any issues that are confirmed 
problems. 


EPA recommends that you develop an inspection schedule that meets the needs of 
your site. You’ll probably also want to update and refine this schedule based on your 
experiences, the findings of your inspections, and the changing conditions at your site. 


28 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 













SWPPP Tip! 


Selecting BMP Inspectors 

A BMP inspection is only as good as the inspector. 
Therefore, it is important to select qualified 
personnel to conduct BMP inspections. The 
SWPPP should identify who has the responsibility 
for conducting inspections. Personnel selected 
to conduct inspections should be knowledgeable 
in the principles and practices of erosion and 
sediment controls, possess the technical skills 
to assess conditions at the construction site that 
could impact stormwater quality, and assess the 
effectiveness of any sediment and erosion control 
measures selected. 

Several states and other organizations offer 
training that will help prepare inspectors 
to accurately evaluate BMPs, decide when 
maintenance is appropriate, or when a different 
BMP should be substituted. (Several states 
require that sites be inspected by someone that 
the state certifies as a qualified inspector.) One 
national organization offers two certification 
programs that would be useful for personnel 
who are developing and implementing SWPPPs 
and conducting inspections. These certification 
programs are called: “ Certified Professional in 
Erosion and Sediment Control (CPESC)" and 
“Certified Professional in Stormwater Quality 
(CPSWQ)." You can find more information on 
these programs at www.cpesc.org 

Inspection Reports 

Complete an inspection report after each 
inspection. You should retain copies of all 
inspection reports and keep them with or 
in your SWPPP. Generally, the following 
information is required to be included in your 
inspection report: 

• Inspection date 

• Inspector information, including the 
names, titles, and qualifications of 
personnel conducting the inspection 

• Weather information for the period 
since the last inspection (or for the first 
inspection since commencement of 
construction activity) including a best 
estimate of the beginning of each storm, its 
duration, approximate amount of rainfall 
for each storm (in inches), and whether any 
discharges occurred. You may create a log 
to record the basic weather information or 
you may keep copies of weather information 
from a reliable local source, such as the 
internet sites of local newspapers, TV 
stations, local universities, etc. 

• Current weather information and a 
description of any discharges occurring at 
the time of the inspection 


• Descriptions of evidence of previous or 
ongoing discharges of sediment or other 
pollutants from the site 

• Location(s) of BMPs that need to be 
maintained 

• Location(s) of BMPs that failed to oper¬ 
ate as designed or proved inadequate for a 
location 

• Location(s) where additional BMPs are 
needed but did not exist at the time of 
inspection 

• Corrective action required, including any 
necessary changes to the SWPPP and 
implementation dates 

• Reference to past corrective actions 
documenting follow-up actions taken 

Consider taking digital photographs during 
inspections to document BMPs, problems 
identified, and progress in implementing the 
SWPPP. 

Appendix B includes an example storm¬ 
water inspection report. You should use this 
report, or a similar report, to document your 
stormwater construction site inspections. 
Check to see if your state or local authority 
has developed an inspection checklist for 
your use. The inspection report is broken up 
into two main sections—site-specific BMPs 
and overall site issues. For the site-specific 
BMPs, you should number the structural and 
non-structural BMPs in your SWPPP on a 
copy of your site map (preferably in the order 
in which you would inspect them on the 
site). Then as you conduct your inspections, 
you can verify whether each BMP has been 
installed and maintained. If a BMP has not 
been installed or needs maintenance, describe 
this in the corrective action section and list 
a date for when the corrective action will 
be completed and who will be responsible 
for completing the action. The overall site 
issues section describes 11 common issues at 
construction sites you should inspect for. You 
can customize this form to meet the needs of 
your particular situation. 

Make sure each inspection report is signed 
and certified consistent with your permit’s 
requirements. 

Chapter 8, Section D contains more 
information on implementing an inspection 
program. Also, see the suggested inspection 
report form in Appendix B. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


29 






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SWPPP Tip! 


Consider More Effective BMPs 

During inspections, consider whether the installed 
BMPs are working effectively. If you find a BMP 
that is failing or overwhelmed by sediment, you 
should consider whether it needs to be replaced 
with a more effective BMP or enhanced by the 
addition of another, complimentary BMP. Ensure 
that you record such changes in your SWPPP and 
on your site map. 


6. BMP Maintenance 

Implementing a good BMP maintenance 
program is essential to the success of your 
SWPPP and to your efforts to protect nearby 
waterways. You should conduct maintenance 
of BMPs regularly and whenever an 
inspection (formal or informal) identifies a 
problem or potential issue. For instance, trash 
and debris should be cleaned up, dumpsters 
should be checked and covered, nearby streets 
and sidewalks should be swept daily, and so 
on. Maintenance on erosion and sediment 
controls should be performed as soon as site 
conditions allow. Consider the following 
points when conducting maintenance: 

• Follow the designers or manufacturer’s 
recommended maintenance procedures for 
all BMPs 

• Maintenance of BMPs will vary according 
to the specific area and site conditions 

• Remove sediment from BMPs as 
appropriate and properly dispose of 
sediment into controlled areas to prevent 
soil from returning to the BMP during 
subsequent rain events 

• Remove sediment from paved roadways 
and from around BMPs protecting storm 
drain inlets 

• Ensure that construction support activities, 
including borrow areas, waste areas, 
contractor work areas, and material storage 
areas and dedicated concrete and asphalt 
batch plants are cleaned and maintained 

• Replace damaged BMPs, such as silt fences, 
that no longer operate effectively 

You should keep a record of all maintenance 
activities, including the date, BMP, location, 
and maintenance performed in your SWPPP. 


C. Recordkeeping 

You must keep copies of the SWPPP, 
inspection records, copies of all reports 
required by the permit, and records of all data 
used to complete the NOI to be covered by 
the permit for a period of at least 3 years from 
the date that permit coverage expires or is 
terminated. 

Records should include: 

• A copy of the SWPPP, with any 
modifications 

• A copy of the NOI and Notice of 
Termination (NOT) and any stormwater- 
related correspondence with federal, state, 
and local regulatory authorities 

• Inspection forms, including the date, place, 
and time of BMP inspections 

• Names of inspector(s) 

• The date, time, exact location, and a 
characterization of significant observations, 
including spills and leaks 

• Records of any non-stormwater discharges 

• BMP maintenance and corrective actions 
taken at the site (Corrective Action Log) 

• Any documentation and correspondence 
related to endangered species and historic 
preservation requirements 

• Weather conditions (e.g., temperature, 
precipitation) 

• Date(s) when major land disturbing 
(e.g. clearing, grading, and excavating) 
activities occur in an area 

• Date(s) when construction activities are 
either temporarily or permanently ceased 
in an area 

• Date(s) when an area is either temporarily 
or permanently stabilized 


30 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 








Chapter T. Certification and Notification 


A. Certification 

Signature and Certification 

The construction site operator must sign the permit application form, which is often 
called a Notice of Intent or NOI. (In some instances, the construction general permit 
may not require the submission of an NOI or application. Construction activities may 
be covered automatically.) 

All reports, including SWPPPs and inspection reports, generally must be signed by 
the construction site operator or a duly authorized representative of that person. 

The authorized representative is typically someone who has direct responsibility 
for implementing the SWPPP. If the operator chooses to designate an authorized 
representative, a signed letter or statement to that effect must be included in the 
SWPPP. Check your permit for exact requirements. 

Your SWPPP must include the signature of the construction site operator or 
authorized representative and the certification statement provided in the general 
permit. An example of the certification language from EPA’s Construction General 
Permit follows: 

“I certify under penalty of law that this document and all attachments were 
prepared under my direction or supervision in accordance with a system designed 
to assure that qualified personnel properly gathered and evaluated the information 
submitted. Based on my inquiry of the person or persons who manage the 
system, or those persons directly responsible for gathering the information, the 
information submitted is, to the best of my knowledge and belief, true, accurate, 
and complete. I am aware that there are significant penalties for submitting false 
information, including the possibility of fine and imprisonment for knowing 
violations.” 


► This chapter 
describes how, 
after developing 
your SWPPP, you 
can obtain permit 
coverage for 
your stormwater 
discharges. 


This ensures that the SWPPP was developed and reviewed by a 
responsible party with the ability to implement the BMPs and 
other commitments described in the SWPPP. 

Copy of Permit Requirements 

Most general permits require you to keep a copy of the 
permit and your NOI with your SWPPP. This allows you to 
quickly check the permit if a question arises about a permit 
requirement. 

Other State, Tribal, and Local Programs 


SWPPP Tip! 


Posting a sign at the construction 
entrance 

EPA and many state general permits require that 
you post a sign or other notice conspicuously 
near the main entrance of the construction site. 
EPA’s permit requires that the sign contain a 
copy of the NOI, the location of the SWPPP, and 
a contact person for viewing the SWPPP. 


Include in your SWPPP a description of any other federal, state, 
tribal, or local requirements for erosion and sediment control 

and stormwater management that apply to your site. Many local governments also im¬ 
pose erosion and sediment control requirements; your SWPPP should comply with both 
the general permit and any applicable local requirements. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


31 






■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ 


■■■■■■■■■■■■■■■■■■■■■■■■■ 


■■■■■■■■ 


W SWPPP Tip! 


Making your SWPPP available 

While EPA and most states do not require you 
to submit a copy of your SWPPP for review, your 
SWPPP must be available to these and other 
government agencies for inspection. Your permit 
may also require you to make your SWPPP 
available to the public, if requested. If you have 
the ability, you should consider posting your 
SWPPP on the Internet and publicizing the URL. 
Check your permit for exact requirements. 


B. Notification 

Now that you have developed your SWPPP 
and before you begin construction, you 
must begin the process of obtaining permit 
coverage from your authorized state or EPA. 
Authorized states and EPA use general permits 
to cover all construction sites. These broadly 
written general or umbrella permits apply to 
all construction activities in a given state. 

Obtaining Coverage Under a General Permit 

Important! Before obtaining permit 
coverage, you should read a copy of the 
appropriate construction general permit and 
develop your SWPPP. 

To obtain coverage under a state or EPA 
construction general permit, you will typically 
need to fill out and submit an application 
form, often called a Notice of Intent or NOI. 
Submitting this form to the permitting 
authority indicates your intent to be 
authorized to discharge stormwater under the 
appropriate general permit for construction 
activities. Depending on the permit, you may 
be authorized to discharge immediately or at 
some later time. In some cases, you are not 
authorized to discharge until the state has 
notified you accordingly. EPA’s Construction 
General Permit requires a 7-day waiting 
period after a complete NOI is received and 
posted on EPA’s website (www.epa.gov/ 
npdes/noisearch). The waiting period expires 
when the permit’s status changes from 
waiting to active. 


Take a Closer Look... 

Information on the Application or Notice of 
Intent (NOI) 

The NOI provides the permitting authority with 
pertinent information about your construction 
site, such as owner/operator information, site 
location, estimated project start and completion 
dates, approximate area to be disturbed, 
information about your SWPPP, receiving waters, 
and endangered species review certification. 

An appropriate person who is authorized to 
represent your organization must sign and verify 
that the facts contained in the NOI are true and 
accurate. For businesses, a certifying official is 
typically a corporate officer, such as a president, 
vice president, or manager of operations. For 
municipalities, it’s typically a principal executive 
officer or ranking elected official. Check your 
permit for exact signature requirements. 

In general, the only information you need to 
submit to the permitting authority is the NOI. 

EPA and most authorized state agencies do not 
require you to submit your SWPPP for approval. 
Flowever, many local governments review and 
approve at least the erosion and sediment control 
component of your SWPPP. 

What does this mean to me? 

There are significant penalties for failing 
to obtain authorization to discharge or 
for submitting inaccurate information. If 
you are the certifying official, make sure 
you are authorized to discharge before 
construction activities begin. 


SWPPP Tip! 


Deadline for submitting NOIs under 
EPA’s Construction General Permit 

For EPA’s construction general permit, the 
fastest and easiest way to obtain permit 
coverage is to use EPA’s electronic permit 
application system, called “eNOI” at www.epa. 
gov/npdes/stormwater/enoi. Using this approach, 
you may be authorized to discharge in as little as 
7 days after submission of your electronic NOI. 

If you choose to submit your NOI by mail, EPA 
recommends that you send it at least one month 
before you need permit coverage. 


32 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 











Chapter 8: SWPPP Implementation 


A. Train Your Staff and Subcontractors 

Your site’s construction workers and subcontractors might not be familiar with 
stormwater BMPs, and they might not understand their role in protecting local 
rivers, lakes and coastal waters. Training your staff and subcontractors in the basics 
of erosion control, good housekeeping, and pollution prevention is one of the most 
effective BMPs you can institute at your site. 

Basic training should include 

• Spill prevention and cleanup measures, including the prohibition of dumping any 
material into storm drains or waterways 

• An understanding of the basic purpose of stormwater BMPs, including what 
common BMPs are on-site, what they should look like, and how to avoid damaging 
them 

• Potential penalties associated with stormwater noncompliance 


► Your SWPPP is your 
guide to preventing 
stormwater pollution. 
However, it is just a 
plan. Implementing 
your SWPPP, 
maintaining your 
BMPs, and then 
constantly reevaluating 
and revising your BMPs 
and your SWPPP are 
the keys to protecting 
your local waterways. 


Staff directly responsible for implementing the SWPPP should receive comprehensive 
stormwater training, including 

• The location and type of BMPs being implemented 

• The installation requirements and water quality purpose for each BMP 


• Maintenance procedures for each of the 
BMPs being implemented 

• Spill prevention and cleanup measures 

• Inspection and maintenance 
recordkeeping requirements 

You can train staff and subcontractors 
in several ways: short training sessions 
(food and refreshments will help increase 
attendance), posters and displays explaining 
your site’s various BMPs, written agreements 
with subcontractors to educate their staff 
members, signs pointing out BMPs and 
reminders to keep clear of them. Every 
construction site operator should try to train 
staff and subcontractors to avoid damaging 
BMPs. By doing so, operators can avoid the 
added expense of repairs. 


SWPPP Tip! 


Train your staff and subcontractors! 

Here are a few key things you will want to cover with each person 

working on your site: 

• Use only designated construction site entrances 

• Keep equipment away from silt fences, fiber rolls, and other 
sediment barriers 

• Know the locations of disposal areas, and know the proper 
practices for trash, concrete and paint washout, hazardous 
chemicals, and so on 

• Keep soil, materials, and liquids away from paved areas and storm 
drain inlets. Never sweep or wash anything into a storm drain 

• Know the location and understand the proper use of spill kits 

• Know the locations of your site’s designated protection areas. 

Keep equipment away from.stream banks, valuable trees and 
shrubs, and steep slopes. Clearly mark these areas with signs 

• Keep equipment off mulched, seeded, or stabilized areas. Post 
signs on these areas, too 

• Know who to contact when problems are identified! 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


33 





B. Ensure Responsibility—Subcontractor 
Agreements 

At any given site, there might be multiple 
parties (developer, general contractor, 
builders, subcontractors) that have roles and 
responsibilities for carrying out or maintaining 
stormwater BMPs at a given site. These roles 
and responsibilities should be documented 
clearly in the SWPPP (see Chapter 2, Section 
D). In some cases (state requirements vary), 
there may be one entity that has developed 
the SWPPP and filed for permit coverage 
and, therefore, is designated as the operator. 
When other parties at a site are not officially 
designated as operators, many operators are 
incorporating the roles and responsibilities 
of these non-operators in the agreements and 
contracts they have with these companies 
and individuals. This contract language 
should spell out responsibilities implementing 
and maintaining stormwater BMPs, for 
training staff, and for correcting damage to 
stormwater BMPs on the site. Several states 
have stormwater regulations that hold other 
parties liable even if they are not identified as 
the operator. 

C. Implement Your SWPPP Before 
Construction Starts 

Once you have obtained permit coverage and 
you are ready to begin construction, it is time 
to implement your SWPPP. You must implement 
appropriate parts of your SWPPP before 
construction activity begins. This generally 
involves installing storm drain inlet protection, 
construction entrances, sediment basins, and 
perimeter silt fences before clearing, grading, 
and excavating activities begin. 

After construction activities begin, your 
SWPPP should describe when additional 
erosion and sediment controls will be installed 
(generally after initial clearing and grading 
activities are complete). You should also begin 
BMP inspections once clearing and grading 
activities begin. 


SWPPP Tip! 


Take Photographs During Inspections 

Taking photographs can help you document areas that need 
maintenance and can help identify areas where subcontractors might 
need to conduct maintenance. Photographs can also help provide 
documentation to EPA or state inspectors that maintenance is being 
performed. 


SWPPP Tip! 


Prepare for the rain and snowmelt! 

In some areas of the country, construction 
site operators are required to develop weather 
triggered action plans that describe additional 
activities the operator will conduct 48 hours 
before a predicted storm (at least a 50 percent 
forecasted chance of rain). It is also a good idea 
to stockpile additional erosion and sediment 
control BMPs (such as silt fencing, and fiber 
rolls) at the site for use when necessary. 


D. Conduct Inspections and Maintain 
BMPs 

As mentioned earlier (Chapter 6), EPA 
recommends that you develop an inspection 
schedule for your site that considers the size, 
complexity, and other conditions at your 
site. This should include regularly scheduled 
inspections and less formal inspections. 

EPA recommends that you develop a plan 
that includes inspections before and after 
anticipated rain events. You might also want 
to inspect some BMPs during rain events 
to see if they are actually keeping sediment 
on site! Conducting inspections during rain 
events also allows a construction site operator 
to address minor problems before they turn 
into major problems. 

Temporarily Removed BMPs 

BMPs sometimes need to be temporarily 
removed to conduct work in an area of the 
site. These temporarily removed BMPs should 
be noted on the site plan and replaced as soon 
as possible after the completion of the activity 
requiring their removal. If a rain is forecast, 
the BMPs should be replaced as soon as 
possible before the rain event. 


34 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 





Recommended Inspection Sequence 

You should conduct thorough inspections of your site, making sure to inspect all areas and 
BMPs. The seven activities listed below are a recommended inspection sequence that will help 
you conduct a thorough inspection (adapted from MPCA 2004). 


1. Plan your inspection 

0 Create a checklist to use during the 
inspection (see Appendix B) 

0 Obtain a copy of the site map with BMP 
locations marked 

0 Plan to walk the entire site, including 
discharge points from the site and 
any off-site support activities such as 
concrete batch plants should also be 
inspected 

0 Follow a consistent pattern each time 
to ensure you inspect all areas (for 
example, starting at the lowest point and 
working uphill) 

2. Inspect discharge points and downstream, 

off-site areas 

0 Inspect discharge locations to determine 
whether erosion and sediment control 
measures are effective 

0 Inspect nearby downstream locations, if 
feasible 

0 Walk down the street to inspect off-site 
areas for signs of discharge. This is 
important in areas with existing curbs 
and gutters 

0 Inspect downslope municipal catch basin 
inlets to ensure that they are adequately 
protected 

3. Inspect perimeter controls and slopes 

0 Inspect perimeter controls such as silt 
fences to determine if sediment should 
be removed 

0 Check the structural integrity of the BMP 
to determine if portions of the BMP need 
to be replaced 

0 Inspect slopes and temporary stockpiles 
to determine if erosion controls are 
effective 

4. Compare BMPs in the site plan with the 

construction site conditions 

0 Determine whether BMPs are in place as 
required by the site plan 


0 Evaluate whether BMPs have been 
adequately installed and maintained 

0 Look for areas where BMPs are needed 
but are missing and are not in the 
SWPPP 

5. Inspect construction site entrances 

0 Inspect the construction exits to 

determine if there is tracking of sediment 
from the site onto the street 

0 Refresh or replace the rock in designated 
entrances 

0 Look for evidence of additional 

construction exits being used that are 
not in the SWPPP or are not stabilized 

0 Sweep the street if there is evidence of 
sediment accumulation 

6. Inspect sediment controls 

0 Inspect any sediment basins for sediment 
accumulation 

0 Remove sediment when it reduces the 
capacity of the basin by the specified 
amount (many permits have specific 
requirements for sediment basin 
maintenance. Check the appropriate 
permit for requirements and include 
those in your SWPPP) 

7. Inspect pollution prevention and good 

housekeeping practices 

0 Inspect trash areas to ensure that waste 
is properly contained 

0 Inspect material storage and staging 
areas to verify that potential pollutant 
sources are not exposed to stormwater 
runoff 

0 Verify that concrete, paint, and stucco 
washouts are being used properly and 
are correctly sized for the volume of 
wash water 

0 Inspect vehicle/equipment fueling 
and maintenance areas for signs of 
stormwater pollutant exposure 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


35 





Common Compliance Problems During Inspections 

The following are problems commonly found at construction sites. As you conduct your inspections, look for these problems on your site 
(adapted from MPCA 2004). 

Problem #1—Not using phased grading or providing temporary or permanent cover (i.e., soil stabilization) 

In general, construction sites should phase their grading activities so that only a portion of the site is exposed at any one time. Also, disturbed areas 
that are not being actively worked should have temporary cover. Areas that are at final grade should receive permanent cover as soon as possible. 

Problem #2—No sediment controls on-site 

Sediment controls such as silt fences, sediment barriers, sediment traps and basins must be in place before soil-disturbance activities begin. 
Don’t proceed with grading work out-of-phase. 

Problem #3—No sediment control for temporary stockpiles 

Temporary stockpiles must be seeded, covered, or surrounded by properly installed silt fence. Stockpiles should never be placed on paved 
surfaces. 

Problem #4—No inlet protection 

All storm drain inlets that could receive a discharge from the construction site must be protected before construction begins and must be main¬ 
tained until the site is finally stabilized. 

Problem #5—No BMPs to minimize vehicle tracking onto the road 

Vehicle exits must use BMPs such as stone pads, concrete or steel wash racks, or equivalent systems to prevent vehicle tracking of sediment. 

Problem #6—Improper solid waste or hazardous waste management 

Solid waste (including trash and debris) must be disposed of properly, and hazardous materials (including oil, gasoline, and paint) must be prop¬ 
erly stored (which includes secondary containment). Properly manage portable sanitary facilities. 

Problem #7—Dewatering and other pollutant discharges at the construction site 

Construction site dewatering from building footings or other sources should not be discharged without treatment. Turbid water should be filtered or 
allowed to settle. 

Problem #8—Poorly managed washouts (concrete, paint, stucco) 

Water from washouts must not enter the storm drain system or a nearby receiving water. Make sure washouts are clearly marked, sized ad¬ 
equately, and frequently maintained. 

Problem #9—Inadequate BMP maintenance 

BMPs must be frequently inspected and maintained if necessary. Maintenance should occur for BMPs that have reduced capacity to treat storm¬ 
water (construction general permits or state design manuals often contain information on when BMPs should be maintained), or BMPs that have 
been damaged and need to be repaired or replaced (such as storm drain inlet protection that has been damaged by trucks). 

Problem #10—Inadequate documentation or training 

Failing to develop a SWPPP, keep it up-to-date, or keep it on-site, are permit violations. You should also ensure that SWPPP documentation such 
as a copy of the NOI, inspection reports and updates to the SWPPP are also kept on-site. Likewise, personnel working on-site must be trained on 
the basics of stormwater pollution prevention and BMP installation/maintenance. 


Like your construction site, your SWPPP 
is dynamic. It is a document that must be 
amended to reflect changes occurring at the 
site. As plans and specifications change, 
those changes should be reflected in your 
SWPPP. If you find that a BMP is not working 
and you decide to replace it with another, 
you must reflect that change in your SWPPP. 
Document in your SWPPP transitions from 
one phase of construction to the next, and 
make sure you implement new BMPs required 
for that next phase. 


E. Update and Evaluate Your SWPPP 


process. An informal analysis of both your 
inspection’s findings and your list of BMP 
repairs will often reveal an inadequately 
performing BMP. An inspection immediately 
after a rain event can indicate whether 
another approach is needed. 


You may decide to remove an existing BMP 
and replace it with another, or you may add 
another BMP in that area to lessen the impact 
of stormwater on the original installation. 


Are Your BMPs Working? 

You should evaluate the effectiveness of your 
BMPs as part of your routine inspection 


When you update your SWPPP, you can 
simply mark it up, particularly for relatively 
simple changes and alterations. More 
significant changes might require a rewriting 
of portions of the SWPPP. The site map should 
also be updated as necessary. 


36 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 





Chapter 9: Final Stabilization and Permit 
Termination 


Stabilize Disturbed Areas 

As your construction project progresses, you must stabilize areas not under 
construction. EPA and most states have specific requirements and time frames that 
must be followed. Generally, it is a wise management practice to stabilize areas 
as quickly as possible to avoid erosion problems that could overwhelm silt fences, 
sediment basins, and other sediment control devices. 


► This chapter describes 
what you must do 
to stabilize your 
construction site and 
end permit coverage. 


W SWPPP Tip! 


Stabilize as soon as practicable 

EPA’s Construction General Permit states that, 
“stabilization measures must be initiated as soon 
as practicable in portions of the site where con¬ 
struction activities have temporarily or perma¬ 
nently ceased, but in no case more than 14 days 
after the construction activity in that portion of 
the site has temporarily or permanently ceased.” 


Temporary stabilization can be achieved through a variety of BMPs, including 
mulching, seeding, erosion control blankets, hydroseeding, and other measures. 

Permanent or final stabilization of areas on your site is generally accomplished by 
installing the final landscape requirements (e.g., trees, grass, gardens, or permanent 
stormwater controls). Once the site has been stabilized, you can terminate your 
permit coverage. 

Sediment controls, such as silt fence, berms, sediment ponds or traps, alone, are not 
stabilization measures. You should continue to use these kinds of measures (e.g., silt 
fence around an area that has been seeded) until full stabilization is achieved. 

A. Final Stabilization 

When you have completed your construction 
project or an area within the overall project, 
you must take steps to permanently and finally 
stabilize it. Check your permit for the specific 
requirements you must meet. After a project or an 
area in the project has been fully stabilized, you 
should remove temporary sediment and erosion 
control devices (such as silt fences). You might 
also be able to stop routine inspections in these 
stabilized areas. However, in some states such as 
Colorado, inspections are required every 30 days 
(after the construction has been completed and the 
site is stabilized) until permit coverage has been 

terminated. In general, you should be aware that Figure 16. Seeding is an effective BMP that can be used to temporarily or 

permanently stabilize disturbed areas. 



Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


37 








final stabilization often takes time (weeks 
or even months), especially during times of 
low rainfall or during the colder months of 
the year. You should not discontinue routine 
inspections until you have met the final 
stabilization requirements in your permit. 

EPA and many states define final stabilization 
as occurring when a uniform, evenly 
distributed perennial vegetative cover with a 
density of 70 percent of the native background 
cover has been established on all unpaved 
areas and areas not covered by permanent 
structures. Some states have a higher 
percentage of vegetative cover required (e.g., 
New York requires 80 percent). Please review 
your state’s construction general permit for 
specific requirements. 

Native vegetation must be established 
uniformly over each disturbed area on 
the site. Stabilizing seven of ten slopes, or 
leaving an area equivalent to 30 percent of 
the disturbed area completely unstabilized 
will not satisfy the uniform vegetative cover 
standard. 

The contractor must establish vegetation over 
the entire disturbed soil area at a minimum 
density of 70 percent of the native vegetative 
coverage. For example, if native vegetation 
covers 50 percent of the undisturbed ground 
surface (e.g., in an arid or semi-arid area), 
the contractor must establish 35 percent 
vegetative coverage uniformly over the entire 
disturbed soil area (0.70 x 0.50 = 0.35 or 
35 percent). Several states require perennial 
native vegetative cover that is self-sustaining 
and capable of providing erosion control 
equivalent to preexisting conditions to satisfy 
the 70 percent coverage requirement. 

In lieu of vegetative cover, you can apply 
alternate measures that provide equivalent 
soil stabilization to the disturbed soil area. 
Such equivalent measures include blankets, 
reinforced channel liners, soil cement, 
fiber matrices, geotextiles, or other erosion- 
resistant soil covering or treatments. Your 
construction general permit might allow 
all or some of these alternate measures 
for equivalent soil stabilization for final 
stabilization; check your general permit. 


B. Permit Termination 

Once construction activity has been 
completed and disturbed areas are finally 
stabilized, review your general permit for 
specific steps to end your coverage under 
that permit. EPA and many states require 
you to submit a form, often called a notice 
of termination (NOT), to end your coverage 
under that construction general permit. Before 
terminating permit coverage, make sure you 
have accomplished the following: 

• Remove any construction debris and trash 

• Remove temporary BMPs (such as silt 
fence). Remove any residual sediment as 
needed. Seed and mulch any small bare 
spots. BMPs that will decompose, including 
some fiber rolls and blankets, may be left 
in place 

• Check areas where erosion-control blankets 
or matting were installed. Cut away 

and remove all loose, exposed material, 
especially in areas where walking or 
mowing will occur. Reseed all bare soil 
areas 

• Ensure that 70 percent of background 
native vegetation coverage or equivalent 
stabilization measures have been applied 
for final soil stabilization of disturbed areas 

• Repair any remaining signs of erosion 

• Ensure that post-construction BMPs are 
in place and operational. Provide written 
maintenance requirements for all post¬ 
construction BMPs to the appropriate party 

• Check all drainage conveyances and outlets 
to ensure they were installed correctly 
and are operational. Inspect inlet areas to 
ensure complete stabilization and remove 
any brush or debris that could clog inlets. 
Ensure banks and ditch bottoms are well 
vegetated. Reseed bare areas and replace 
rock that has become dislodged 

• Seed and mulch or otherwise stabilize any 
areas where runoff flows might converge or 
high velocity flows are expected 

• Remove temporary stream crossings. Grade, 
seed, or re-plant vegetation damaged or 
removed 

• Ensure subcontractors have repaired their 
work areas before final closeout 

You might also be required to file an NOT if 
you transfer operational control to another 


38 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 




mmmmm 






Take a Closer Look... 

Is there a deadline to submit an NOT? 


Many states require a Notice of Termination (NOT) or similar form to indicate that the construction phase 
of a project is completed and that all the terms and conditions have been met. This notification informs 
the permitting authority that coverage under the construction general permit is no longer needed. If your 
permitting authority requires such a notification, check to see what conditions must be met in order 
to submit it and check to see if there is a deadline for 
submission. EPA’s Construction General Permit requires 

mat u . , What does this mean to me? 

that you submit an NOT when you have met all your permit 

TL .... ^ „ Check your permit carefully for details 

requirements. The NOT is due no later than 30 days after m(j condltiom rel3ting t0 lerminating 

meeting these requirements. your permit coverage. 


party before the project is complete. The new 
operator would be required to develop and 
implement a SWPPP and to obtain permit 
coverage as described above. 

EPA and most states allow homebuilders to 
terminate permit coverage when the property 
has been transferred to the homeowner with 
temporary or final stabilization measures in 
place. If the transfer is made with temporary 
stabilization measures in place, EPA expects 
the homeowner to complete the final 
landscaping. Under these circumstances, EPA 
and most states do not require homeowners 
to develop SWPPPs and apply for permit 
coverage. 


C. Record Retention 

EPA’s regulations specifies that you must 
retain records and reports required in the 
permit, including SWPPPs and information 
used to complete the NOI, for at least 
3 years from the termination of coverage or 
expiration of the permit. You should also keep 
maintenance and inspection records related to 
the SWPPP for this same time frame. General 
permits issued by states may have a longer 
period for retention. 



Figure 17. Make sure inlets, outlets, and slopes are well stabilized before leaving 
the site and filing your “Notice of Termination” for ending permit coverage. 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


39 









References 


American Society of Civil Engineers (ASCE) and Water Environment Federation (WEF). 
1992. Design and Construction of Urban Stormwater Management Systems 

Arendt, R. 1996. Conservation Design for Subdivisons: A Practical Guide to Creating 
Open Space Networks. American Planning Association Planners Book Service. Chicago, 
IL. 

Claytor, R. 2000. Practical tips for construction site phasing. Article 54 in The Practice of 
Watershed Protection. Center for Watershed Protection, Ellicott City, MD, pp. 317-322. 

Dunne, T. and L. Leopold. 1978. Water and Environmental Planning. 

Environmental Protection Agency (EPA). 1993. Guidance Specifying Management 
Measures for Sources of Nonpoint Pollution in Coastal Waters. 840-B-92-002. Office 
of Water. Washington, DC. 

Maryland Department of the Environment (MDE). 2000. Maryland Stormwater Design 
Manual: Volumes 1 and 2. Maryland Department of the Environment, Baltimore, MD. 

< www.mde.state.md.us/environment/wma/stormwatermanual > 

Minnesota Pollution Control Agency (MPCA). 2004. Stormwater Construction Inspection 
Guide. < www.pca.state.mn.us/publications/wq-strm2-10.pdf> 

National Arbor Day Foundation. No date. The Value of Trees to a Community. 

< www.arborday.org/trees/Benefits.cfm > 

Natural Resources Conservation Service (NRCS). 2000. 1997 National Resources Inventory 
Summary Report. 

<http://www.nrcs.usda.gov/TECHNICAL/NRI/1997/summary_report/> 

Natural Resources Conservation Service (NRCS). 2006. National Resources Inventory 2003 
Annual NRI - Soil Erosion. 

<http://www.nrcs.usda.gov/Technical/land/nri03/SoilErosion-mrb.pdf> 

Robertson, B., R. Pitt, A. Ayyoubi, and R. Field. 1995. A Multi-Chambered Stormwater 
Treatment Train. In Proceedings of the Engineering Foundation Conference: 

Stormwater NPDES-Related Monitoring Needs, Mt. Crested Butte, Colorado, August 7-12, 
1994, American Society of Civil Engineers, New York, NY. 

Terrene Institute. 2001. Landscaped rain gardens offer stormwater control. Nonpoint Source 
News-Notes 66:18-20. 


Acknowledgements 

The graphics used in this guide were developed by Tetra Tech, Inc. for the Kentucky 
Divison of Water’s Erosion and Sediment Control Field Guide. 


40 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 




Appendix A: SWPPP Template 


An electronic copy of the SWPPP template is available on EPA’s web site at: 

http://wwvv.epa.gov/npdes/swpppguide 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


41 




Appendix B: Sample Inspection Report 


An electronic copy of the sample inspection report is available on EPA’s web site at: 

http://www.epa.gov/npdes/swpppguide 


42 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 





Appendix C: Calculating the Runoff Coefficient 


The following information is largely taken from EPA’s 1992 guidance Stormwater 
Management for Construction Activities: Developing Pollution Prevention Plans and Best 
Management Practices (EPA 832-R-92-005). 

It is important to estimate your development’s impact on runoff after construction is 
complete. This can be done by estimating the runoff coefficient for pre- and post-construction 
conditions. The runoff coefficient (“C” value) is the partial amount of the total rainfall 
which will be come runoff. The runoff coefficient is used in the “rational method” which is: 

Q = CiA, 

Where Q = the rate of runoff from an area, 
i = rainfall intensity, and 
A = the area of the drainage basin. 

There are many methods which can be used to estimate the amount of runoff from a 
construction site. You are not required to use the rationale method to design stormwater 
conveyances or BMPs. Consult your State/local design guides to determine what methods to 
use for estimating design flow rates from your development. 

The less rainfall that is absorbed (infiltrates) into the ground, evaporates, or is otherwise 
absorbed on site, the higher the “C” value. For example, the “C” value of a lawn area is 0.2, 
which means that only 20 percent of the rainfall landing on that area will run off, the rest 
will be absorbed or evaporate. A paved parking area would have a “C” value of 0.9, which 
means that 90 percent of the rainfall landing on that area will become runoff. You should 
calculate the runoff coefficient for conditions before construction and after construction is 
complete. It is suggested that a runoff coefficient be calculated for each drainage basin on 
the site. The following is an example of how to calculate the “C” value. 

The runoff coefficient or “C” value for a variety of land uses may be found in Table C-l 
(NOTE: Consult your State/local design guide, if available, to determine if specific “C” 
values are specified for your area). The “C” values provide an estimate of anticipated runoff 
for particular land uses. Most sites have more than one type of land use and therefore more 
than one “C” value will apply. To have a “C” value that represents your site you will need to 
calculate a “weighted C value.” 

Calculating a “Weighted C value” 

When a drainage area contains more than one type of surface material with more than 
one runoff coefficient a “weighted C” must be calculated. This “weighted C” will take 
into account the amount of runoff from all the various parts of the site. A formula used to 
determine the “weighted C” is as follows: 

C = A |C, + A,c, + ... + A,C 
(A, + A 2 + ... + A x ) 

Where A = acres and C = coefficient. 

Therefore, if a drainage area has 15 acres (ac.) with 5 paved acres (C = 0.9), 5 grassed 
acres (C = 0.2), and 5 acres in natural vegetation (C = 0.1), a “weighted C” would be 
calculated as follows: 

C = (5 ac x 0.9) + (5 ac x 0.2) + (5 ac x 0.1) = o.4 
(5 ac + 5 ac + 5 ac) 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


43 






Table C-l. Typical “C” Values 


Description of Area 

Runoff Coefficients 

Business 


Downtown Areas 

0.70-0.95 

Neighborhood Areas 

0.50-0.70 

Residential 


Single-family areas 

0.30-0.50 

Multi-units, detached 

0.40-0.60 

Multi-units, attached 

0.60-0.75 

Residential (suburban) 

0.25-0.40 

Apartment dwelling areas 

0.50-0.70 

Industrial 


Light Areas 

0.50-0.80 

Heavy Areas 

0.60-0.90 

Parks, cemeteries 

0.10-0.25 

Playgrounds 

0.20-0.35 

Railroad yard areas 

0.20-0.40 

Unimproved areas 

0.10-0.30 

Streets 


Asphalt 

0.70-0.95 

Concrete 

0.80-0.95 

Brick 

0.70-0.85 

Drives and Walks 

0.75-0.85 

Roofs 

0.75-0.95 

Lawns - course textured soil (greater than 85% sand) 


Slope: Flat, 2% 

0.05-0.10 

Average, 2-7% 

•0.10-0.15 

Steep, 7% 

0.15-0.20 

Lawns - fine textured soil (greater than 40% clay) 


Slope: Flat, 2% 

0.13-0.17 

Average, 2-7% 

0.18-0.22 

Steep, 7% 

0.25-0.35 


44 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 




















Appendix D: Resources List 


The following are just a few of the many resources available to assist you in developing your SWPPP. 
The inclusion of these resources does not constitute an endorsement by EPA. 

EPA Resources 

EPA Stormwater Construction Website 

http://www.epa.gov/npdes/stormwater/construction 

• EPA’s Construction General Permit (http://www.epa.gov/npdes/stormwater/cgp) 

EPA’s general permit that applies to all construction activity disturbing greater than one acre in 
the states and territories where EPA is the permitting authority. 

• Construction SWPPP Guide, SWPPP Template and inspection form 
(www.epa.gov/npdes/swpppguide) 

A downloadable copy of this guide, the SWPPP template and inspection form. 

• Menu of BMPs (http://www.epa.gov/npdes/stormwater/menuofbmps) 

Site containing over 40 construction BMP fact sheets. Also contains fact sheets on other 
stormwater program areas, and case studies organized by program area. 

National Management Measures to Control Nonpoint Source Pollution from Urban Areas 

http://www.epa.gov/owow/nps/urbanmm/index.html 

Managing Your Environmental Responsibilities: A Planning Guide for Construction and Development 

http://www.epa.gov/compliance/resources/publications/assistance/sectors/constructmyer/ 

myerguide.pdf 

Expedited Settlement Offer Program for Stormwater (Construction) 

http://www.epa.gov/compliance/resources/policies/civil/cwa/esoprogstormwater.pdf 

A supplemental program to ensure consistent EPA enforcement of stormwater requirements at 
construction sites for relatively minor violations. 

Construction Industry Compliance Assistance 

http://www.cicacenter.org 

Plain language explanations of environmental rules for the construction industry. Links to 
stormwater permits and technical manuals for all 50 states. 

Smart Growth and Low Impact Development Resources 

Using Smart Growth Techniques as Stormwater Best Management Practices 

http://www.epa.gov/livablecommunities/pdf/sg_stormwater_BMP.pdf 

Stormwater Guidelines for Green, Dense Development 

http://www.epa.gov/smartgrowth/pdf/Stormwater_Guidelines.pdf 

Protecting Water Resources with Smart Growth 

http://www.epa.gov/smartgrowth/pdf/waterresources_with_sg.pdf 

Parking Spaces / Community Places: Finding the Balance Through Smart Growth Solutions 

http://www.epa.gov/smartgrowth/parking.htm 

EPA Nonpoint Source Low Impact Development site 

http://www.epa.gov/owow/nps/lid/ 

Better Site Design: A Handbook for Changing Development Rules in Your Community 
Available from http://www.cwp.org 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 


45 




State BMP/Guidance Manuals 

Kentucky Erosion Prevention and Sediment Control Field Guide 

http://www.water.ky.gov/permitting/wastewaterpermitting/KPDES/storm/ 

Easy to read field guide describing erosion and sediment control BMP selection, installation and maintenance. 

Minnesota Stormwater Construction Inspection Guide 

http://www.pca.state.mn.us/publications/wq-strm2-10.pdf 

A manual designed to assist municipal construction inspectors in the procedures for conducting a compliance 
inspection at construction sites. 

California Stormwater Quality Association’s Construction Handbook 

http://www.cabmphandbooks.org/Construction.asp 

Delaware Erosion and Sediment Control Handbook 

http://www.dnrec.state.de.us/dnrec2000/Divisions/Soil/Stormwater/StormWater.htm 

Western Washington Stormwater Management Manual - Volume II - Construction Stormwater Pollution 
Prevention 

http://www.ecy.wa.gov/programs/wq/stormwater/manual.html 

Eastern Washington Stormwater Management Manual 

http://www.ecy.wa.gov/biblio/0410076.html 

A guidance document addressing stormwater design and management in more arid climates. 

Certification Programs 

Certified Professional in Erosion and Sediment Control 

http://www.cpesc.org 

Virginia Erosion and Sediment Control Certification Program 

http://www.dcr.virginia.gov/sw/estr&crt2.htm 

Florida Stormwater, Erosion and Sedimentation Control Inspector Certification 

http://www.dep.state.fl.us/water/nonpoint/erosion.htm 

Other Resources 

International Erosion Control Association 
http://www.ieca.org 

A non-profit organization helping members solve the problems caused by erosion and its byproduct — sediment. 

Erosion Control Magazine 

http://www.erosioncontrol.com 

A journal for erosion and sediment control professionals. 

Designing for Effective Sediment & Erosion Control on Construction Sites by Jerald S. Fifield, PH.D., CPESC. 
Available from Forester Press 

http://www.foresterpress.com 

Book describing proven and practical methods for minimizing erosion and sedimentation on construction sites. 

Stormwater Permitting: A Guide for Builders and Developers by National Association of Home Builders (NAHB). 
Available from NAHB http://www.nahb.org 


46 


Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites 

















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